The RF Ministry of Finance in conjunction with the Singapore party has prepared draft amendments to the double taxation avoidance agreement between Russia and Singapore. The text of the amendments has been published at the Federal portal of legal act drafts and currently undergoes expertise.
The draft specifies certain criteria for acknowledgement of permanent representation and provides for more attractive dividend, interest and royalty taxation terms, at large. It is clearly specified that debenture interest is exempted from taxes at the source of payment.
It is specifically pointed out that the provisions of this agreement are not applicable in those cases where it is proved that the receipt of the associated benefits is the basic purpose of this or that transaction.
The amendments to the section regarding the exchange of financial information are not revolutionary ones and are designed, in broad terms, to bring the old version of the agreement into conformity with the up-to-date requirements of the international data exchange standards for tax purposes.