Russia, Cyprus Sign Tax Treaty Protocol

by Lorys Charalambous, Tax-News.com, Cyprus

13 October 2010

Russia and Cyprus have signed a protocol to their double taxation agreement which allows for extensive exchange of tax information and removes Cyprus from the notorious Russian 'blacklist' of jurisdictions which did not demonstrate a sufficient level of cooperation with the Russian tax authorities.

The two countries had initialed a revised double taxation agreement back in April 2009, and the amending document has finally been signed during a one-day visit to the island by Russian President Dmitry Medvedev.

In 2008 Russia added Cyprus to a 'blacklist' of 54 countries, on the grounds that it was an ‘uncooperative territory’. This blacklist was part of an amendment to the Russian tax code which introduced a tax exemption on the repatriation of dividends from foreign subsidiaries of Russian companies, but specifically excluded Russian subsidiaries based in territories and countries on the so-called blacklist.

Many European countries such as Ireland, Luxembourg and Switzerland successfully lobbied the Russian government to be removed from the blacklist, but Cyprus remained on the list due to its apparent failure in the past to fulfil requests for information from the Russian tax authorities.

Medvedev signed another 14 agreements to enhance economic relations with Cyprus on the same day. The Russian President advised that the new accord made business more transparent and confirmed that Cyprus would be removed from the Russian Central Bank's black list.

Cypriot President Demetris Christofias told reporters at a joint news conference in Nicosia that economic economic relations would be strengthened by ensuring that financial and investment relations were untainted. It is thought that hundreds of companies with Russian connections have been set up in Cyprus in order to take advantage of low tax rates. In 2006, 21.6%, or USD28bn, of the USD130bn total accumulated investments in Russia came via Cyprus, while in 2009 Russian deposits in Cypriot banks were said to exceed USD26.35bn.

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