The Protocol to the Malta- Russia Double Tax Treaty and a brief comparison with the case of Cyprus

On the 1st October 2020 the protocol of the Russian Malta Double Tax Treaty (“DTT”) has been signed.

As with the case of Cyprus dividend and interest withholding taxes (“WHT”) have been generally increased to 15%.

There are however certain exceptions:

5% WHT on dividends to the Government and subdivisions, insurance companies ,pension funds and listed on a recognized stock exchange (subject to conditions). These are the same with the Russia-Cyprus DTT.

5% WHT on interest on Bank loans, eurobonds and corporate bonds. In such cases the Russia- Cyprus DTT provides for a 0% WHT.

On Royalties the WHT remained at 5%. In comparison the Russia-Cyprus DTT provides for 0% WHT.

We shall be keeping you updated for the upcoming protocols with Luxembourg and Holland. It is expected that the provisions of the Luxembourg Protocol shall remain the same as with Malta. At the moment we are expecting with much interest the outcome of the Dutch and Russian negotiations. It seems to us that the Russian Federation follows a similar pattern in the renegotiation of its DTTs.

For further information and clarifications please contact us via email at or via telephone +357 22262108.

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