ARTICLE · 04 JANUARY 2012

DTT Luxembourg-Russia - Note Protocol

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On November 21, 2011, the Double Tax Treaty between the Grand-Duchy of Luxembourg and the Russian Federation dated June 28, 1993 (hereafter the "DTT") has been amended by a protocol implementing new important rules aiming to avoid double taxation and to prevent fiscal evasion with respect to taxes on income and capital (hereafter the "Protocol").

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Giuseppe Cafiero

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On November 21, 2011, the Double Tax Treaty between the Grand-Duchy of Luxembourg and the Russian Federation dated June 28, 1993 (hereafter the "DTT") has been amended by a protocol implementing new important rules aiming to avoid double taxation and to prevent fiscal evasion with respect to taxes on income and capital (hereafter the "Protocol"). The Protocol will enter into force in both countries as from January 1, following the date on which the respective ratification procedures have been completed.

The purpose of such amendment is to improve DTT provisions in relation to economic interest, focused on dividend taxation which should then increase the appeal of Luxembourg for Russian investments in Europe. The most important changes can be summarised as follows:

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