Beta Version

Website Last updated:

June 26, 2026

This bilateral agreement between the United Arab Emirates and the Russian Federation, signed in February 2025, establishes a comprehensive framework for the elimination of double taxation and the prevention of tax evasion and avoidance on income and capital. The treaty defines residency and Permanent Establishment parameters (12 months for construction, 6 months for services) and caps standard withholding tax rates at 10% for dividends, interest, and royalties. Notably, complete tax exemptions are granted for income paid to governments or their listed sovereign wealth funds (e.g., ADIA, Mubadala, RDIF, VEB.RF), and the annexed protocol explicitly adapts to modern remote employment models and eliminates legalization or apostille requirements for information exchanges.

Agreement between the Government of the UNITED ARAB EMIRATES and the Government of the RUSSIAN FEDERATION for the Elimination of Double Taxation with Respect to Taxes on Income and on Capital and the Prevention of Tax Evasion and Avoidance

StatusIn Force

Signed on17 February 2025

Entered into force18 July 2013

Amended on-

Terminated on-

The Government of the United Arab Emirates and the Government of the Russian Federation,

Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,

Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third jurisdictions).

Have agreed as follows:

Contents

CHAPTER I - SCOPE OF THE AGREEMENT

Article 1 - Persons Covered

Article 2 - Taxes Covered

CHAPTER II - DEFINITIONS

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

CHAPTER III - TAXATION OF INCOME

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Income from Employment

Article 15 - Directors' Fees

Article 16 - Entertainers and Sportspersons

Article 17 - Pensions

Article 18 - Government Service

Article 19 - Professors and Researchers

Article 20 - Students and Apprentices

Article 21 - Other Income

CHAPTER IV - TAXATION OF CAPITAL

Article 22 - Capital

CHAPTER V - METHODS FOR THE ELIMINATION OF DOUBLE TAXATION

Article 23 - Elimination of Double Taxation

CHAPTER VI - SPECIAL PROVISIONS

Article 24 - Non-Discrimination

Article 25 - Mutual Agreement Procedure

Article 26 - Exchange of Information

Article 27 - Entitlement to Benefits

Article 28 - Members of Diplomatic Missions and Consular Posts

Article 29 - Protocol

Article 30 - Income from Hydrocarbons

CHAPTER VII - FINAL PROVISIONS

Article 31 - Entry into Force

Article 32 - Termination

Protocol

CHAPTER I - SCOPE OF THE AGREEMENT

Article 1Persons Covered

Article 1
Persons Covered