International treaty

Russia: tax treaties

Tax treaties and related documents between the UK and Russia.

• From: HM Revenue & Customs
• Published: 6 September 2006
• Last updated: 4 February 2025 — See all updates

Documents

1994 Russia-UK Double Taxation Convention

PDF, 136 KB, 28 pages

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Details

February 2025: UK suspends Double Taxation Convention

Following Russia’s unlawful action to suspend material provisions of the 1994 UK-Russia Double Taxation Convention in August 2023, the UK continued to honour its treaty obligations. The UK requested that Russia come back into compliance with its international legal obligations. As it has not done so, the UK has now notified Russia of its intention to suspend the Convention.

The UK will revoke the legislation which gives effect to the Convention in UK law. The Convention will cease to have effect from:

• 6 April 2025 for Income Tax and Capital Gains Tax
• 1 April 2025 for Corporation Tax

Domestic tax law will be applicable without reference to the treaty from that time. The terms of the treaty will continue to apply for earlier periods.

Should Russia come back into compliance with its treaty obligations it will be possible to enact new legislation to give effect to the treaty once again in UK law.

Russia suspends Double Taxation Agreements

Russia has suspended substantially all material provisions of many of its Double Taxation Agreements by Presidential decree dated 8 August 2023. This action affects 38 countries’ Double Taxation Agreements including the 1994 UK-Russia Double Taxation Convention, in respect of which the UK received notification from Russia on 15 August 2023.

Russia has suspended substantially all of the UK-Russia Convention, including treatment of dividends, interest, royalties, capital gains, business profits, employment income and pensions, together with protection against discrimination. The provision for elimination of double taxation has not been fully suspended. The suspension likely means that Russia will not honour any agreed limits on what it may tax at source, and that only limited relief from double taxation will be available in Russia.

The UK-Russia Convention does not permit this unilateral action. The government views this action with utmost seriousness.

The UK has asked Russia to reverse the suspension.

The UK considers the treaty to remain in force and is continuing to comply with its terms. The government is considering next steps and will provide further information in due course.

1994 UK-Russia Double Taxation Convention

The Double Taxation Convention entered into force on 15 February 1994.

It is effective in Russia from 1 January 1998 and in the UK from:

• 1 April 1998 for Corporation Tax
• 6 April 1998 for Income Tax and Capital Gains Tax

Published 6 September 2006
Last updated 4 February 2025 + show all updates

1. 4 February 2025

   UK suspends 1994 Russia-UK Double Taxation Convention.

2. 18 August 2023

   Information has been added to the details section as Russia has suspended Double Taxation Agreements.

3. 6 September 2006

   First published.