The protocol to the 2000 income and capital tax treaty between Austria and Russia was signed on 5 June 2018. The protocol is the first to amend the treaty and includes the following main changes:
- Article 2 (Taxes Covered) is amended with respect to Russian taxes;
- Article 10 (Dividends) is amended with the removal of the minimum USD 100,000 participation value requirement for the 5% reduced withholding tax rate where the beneficial owner is a company directly holding at least 10% of the payin…