Details of the amending protocol, signed on 7 October 2010, to the Cyprus - Russia Income and Capital Tax Treaty (1998), have become available.
The withholding tax rates under the Treaty applicable to dividends, interest and royalties remain unchanged. However, the minimum investment required in order to qualify for the lower rate of 5% on dividends is changed from USD 100,000 to EUR 100,000.
Deviations from the OECD Model include that: