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Protocol to tax Treaty between Armenia and Russia Tax Treaty in Force

According to a recent update from the Armenian government, the 2011 protocol to the 1996 income and capital tax treaty with Russia entered into force on 15 April 2013. The main changes made by the protocol include:

  • Article 4 (Resident) is amended with the addition of the provision that if a company is considered resident in both Contracting States, the benefits of the treaty will not apply unless the competent authorities reach mutual agreement on the company's residence for the purpose of the treaty;
  • Article 5 (Permanent Establishment) is amended by reducing the time period for a construction PE to be deemed constituted from 18 months to 12 months;
  • Article 10 (Dividends) is amended by adding the provision that the 5% withholding tax rate for dividends will apply when the beneficial owner directly holds at least 25% of the paying company's capital;
  • Article 11 (Interest) is amended by adding a 10% withholding tax rate on interest payments (originally no withholding tax);
  • Article 12.1 (Capital Gains) is added, which provides that the following capital gains derived by a resident of one Contracting State may be taxed by the other State:
    • Gains from the alienation of immovable property situated in the other State;
    • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State; and
    • Gains from the alienation of shares or other rights in a company, where more than 50% of the company's assets consist directly or indirectly of immovable property situated in the other State;
  • Article 25 (Assistance in Tax Collection) is renamed and replaced (updated); and
  • Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standard for information exchange.

The protocol generally applies from 1 January 2014, although the changes in Articles 25 (Assistance in Tax Collection) and 26 (Exchange of Information) apply from the date of its entry into force.

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