New double taxation agreement signed between China and Russia to further enhance cooperation

On 13 October 2014, China and Russia concluded a new double taxation agreement (DTA) and protocol (together referred to as ‘the new DTA’). The new DTA embodies the new trends in the development of international tax treaty. Main changes in the new DTA include: time threshold for service permanent establishment (PE) decreased to 183 days; withholding tax (WHT) rate on dividends, interest, and royalties reduced to 5%, 5% and 6% respectively; and a standalone limitation of benefits (LOB) article enforced to tackle treaty shopping. Upon entry into force, the new DTA will replace the currently applicable treaty signed in 1994 (1994 DTA) and is expected to further enhance economic cooperation between both countries.