Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter


Responsive image

Protocol to Tax Treaty between Russia and Sweden to Enter into Force

The pending protocol to the 1993 tax treaty between Russia and Sweden will enter into force on 1 July 2019. The protocol, signed 24 May 2018, is the first to amend the treaty and includes the following main changes:

  • The title of the treaty is amended with the reference to "Income" changed to "Income and Capital";
  • The preamble is replaced in line with BEPS standards;
  • Article 2 (Taxes Covered) is amended in respect of both countries;
  • Article 9 (Adjustment of Income) is amended with new corresponding adjustment provisions;
  • Article 10 (Dividends) is amended with new withholding tax provisions, including that a 5% withholding rate applies if the beneficial owner is a company directly holding at least 10% of the paying company's capital and the holding amounts to at least EUR 80,000 or equivalent at the time of actual payment; otherwise, 15%;
  • Article 13 (Capital Gains) is amended with a new provision to provide that gains derived by a resident of a Contracting State from the alienation of shares or similar rights directly or indirectly deriving more than 50% of their value from immovable property situated in the other State may be taxed in that other State;
  • Article 22 (Capital) is added;
  • Article 23 (Elimination of Double Taxation) is amended with the addition of new provisions with respect to taxes on capital;
  • Article 25 (Mutual Agreement Procedure) is updated, including that MAP cases may be submitted to either Contracting State instead of just the taxpayer's State of residence;
  • Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standards for information exchange;
  • Article 27 (Miscellaneous Provisions) is added, which includes the provision that a benefit under the treaty will not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the treaty; and
  • Article 28 (Limitation of Benefits) is added, which includes the provision that an exemption from or reduction of tax provided by the treaty will not apply to the income of companies (and dividends paid by companies) in a Contracting State:
    • That derive income primarily from other states:
      • from banking, shipping, financing, or insurance activities; or
      • by being the headquarters, coordination center or similar entity providing administrative services or other support to a group of companies which carry on business primarily in other states; and
    • The income from such activities bears a significantly lower tax burden under the laws of that State than income from similar activities carried out within that State or from providing services or support to companies carrying on business in the State.

In relation to the new Articles added to the treaty, the subsequent Articles are renumbered accordingly.

The protocol applies from 1 January 2020.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

FX Rates

Global FX Rates including Tax year Average FX Rates and Spot Rates for all Reporting Currencies.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More