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Changes of the Double Tax Treaty between Russian Federation and Republic of Cyprus

On 16 April 2009 the representatives of Russian Federation and the Republic of Cyprus drew the final draft Protocol to Treaty for Avoiding Double Taxation of 1988 between the parties.

The majority of changes will take effect from 01 January 2010, except the article concerning the capital gains tax, which will take effect from January 2014.

The main changes concern the size of investments for application of the preferential rate from 100 000 USD on 100 000 EUR.

Determining of interest rates too will change.

The basic changes concern the questions of exchange of information between the countries, which will be brought in compliance with the model Convention of The Organization for Security and Co-operation in Europe OSCE.

Important changes also took place in definitions of „permanent establishment“, and issues of actual management for checking on the tax residency.