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[PIO] Notice of the Ministry of Finance on the suspension by the Russian Federation of certain provisions of International Treaties of the Russian

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The Republic of Cyprus has been informed through diplomatic channels that the Russian President signed on August 8, 2023, Decree suspending the application of certain provisions of the Double Taxation Avoidance Agreement regarding taxes on income to avoid double taxation with countries that he considers hostile states, such as the United States, Japan, member states of the European Union and others, including Cyprus.

The Decree suspends certain provisions of these agreements with several EU member states and third countries, namely South Korea, the United Kingdom, Albania, Canada, Switzerland, Montenegro, Poland, Hungary, Ireland, Slovakia, Belgium, Slovenia, the Czech Republic, Denmark, Italy, Finland, Finland, Germany, France, Germany, the Czech Republic, Denmark, Italy, France, the Netherlands, Belgium, the Czech Republic, the United Kingdom, the United Kingdom of Great Britain and Northern Ireland, the United Kingdom of Great Britain and Northern Ireland, the United Kingdom of Great Britain and Northern Ireland, the United Kingdom of Great Britain and Northern Ireland, the United Kingdom of Great Britain and Northern Ireland, the United Kingdom of Great Britain and Northern Ireland, and the United States of America. Macedonia, Spain, Lithuania, Iceland, Portugal, Austria, Greece, New Zealand, New Zealand, Australia, Singapore, Malta, Japan.

The Decree states that the agreements are suspended until "the elimination by foreign states of violations of the legitimate economic and other interests of the Russian Federation, the rights of its citizens and legal entities".

The Decree states that, the agreements are suspended until "the elimination by foreign states of violations of the legitimate economic and other interests of the Russian Federation, the rights of its citizens and legal entities".

The Decree states that, the agreements are suspended until "the elimination by foreign states of violations of the legitimate economic and other interests of the Russian Federation, the rights of its citizens and legal entities".

From the adoption of the Decree, the application of reduced tax rates or tax exemption in relation to income covered by the double tax avoidance agreements is suspended.

The provisions of the Cyprus Agreement with the Russian Federation affected are Articles 5-22, 24, 27 and Article 29. In view of the prohibitions already imposed by the Russian Federation on the export of foreign exchange and payments to jurisdictions it considers "hostile" due to the sanctions imposed on it, including Cyprus, and the sanctions imposed on the Russian Federation which have resulted in the disruption of any extensive economic/trade relations with European states, it is not expected that there will be any further consequences of the adoption of this Decree from the non-implementation of the Agreement.

The Ministry of Finance also wishes to confirm that as a member of the European Union the Republic of Cyprus has not had the opportunity for any consultation on this matter and nor has there been any prior consultation with the competent authorities of the Russian Federation regarding the possibility of the suspension of the Agreement or the issuance of an Order by the Russian Federation.

/SX


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