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In a response to the European Union's blacklisting of Russia following the 2022 invasion of Ukraine, Russia has undertaken the unprecedented move of suspending 38 tax treaties with various countries.
The diplomatic maneuver has ignited discussions about potential economic ramifications and countermeasures, particularly in the context of bilateral tax agreements. The United Kingdom, one of the nations affected by Russia's suspension, now finds itself deliberating on the best course of action to address this unilateral decision.
The UK government's reaction to Russia's suspension of the tax treaty between the two countries has been measured but firm. Following the suspension, the UK formally requested that Russia reverse its decision and reinstate the agreement. The British government's response was conveyed through a note published on August 18, acknowledging the situation and expressing its concerns.
"The UK-Russia Convention does not permit this unilateral action. The government views this action with utmost seriousness," the note stated. It also emphasized that the government was considering its next steps and would provide further information in due course.
The suspension of the tax treaty carries significant implications. It likely implies that Russia may no longer adhere to established limits on taxation at the source, and the availability of relief from double taxation within Russia could be restricted.
The decision to suspend the tax treaties was formalized by Russian President Vladimir Putin through a decree, which was reported by the state news agency RIA on August 8. The suspension encompassed treaties with numerous countries, including major players and offshore financial centers.
The UK officially received notification of the treaty suspension on August 15. However, the response of the UK remains uncertain, given the backdrop of existing sanctions imposed on Russian entities and individuals. The UK has already taken measures to exert pressure on Russia through sanctions.
Russia's Ministry of Finance addressed the situation on August 19, indicating that the suspension decision would stand and would only be reconsidered when sanctions against Russia are lifted. The Ministry of Finance justified the move by pointing to the unilateral imposition of economic sanctions by Western countries since 2022, adding that Russia was categorized by the European Union as a non-cooperative jurisdiction for tax purposes.
Russia's suspension of tax treaties has drawn varied responses from different nations. Some countries, such as Denmark, have chosen to terminate their tax treaties with Russia in light of the Ukraine conflict. Others, including the United States, have opted to maintain longstanding agreements despite geopolitical tensions.
The Russian government's stance is rooted in its belief that economic sanctions infringe upon its rights. It asserts that such violations legitimize the suspension of tax treaties as per the Vienna Convention on the Law of Treaties.
Despite the suspension, the UK government asserts that the tax treaty with Russia remains in force, signaling its commitment to the provisions of the convention. It clarified that while significant portions of the UK-Russia Convention have been suspended, the provision for eliminating double taxation has not been entirely affected.
The tax treaty between Russia and the UK was initially signed during the Boris Yeltsin era and came into effect in 1994. It covers various tax aspects, including corporate tax, income tax, and capital gains tax.
As diplomatic tensions persist and nations navigate the complex web of international agreements and obligations, the fate of tax treaties remains uncertain. The unfolding situation underscores the intricate relationship between geopolitical events and economic cooperation on the global stage.
By fLEXI tEAM
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