As you may know, on 8/8/2023 the Russian President has issued a decree on ‘the suspension by the Russian Federation of specific provisions of the international tax treaties of the Russian Federation’. The decree suspends various provisions of Tax treaties with 38 “unfriendly foreign states”.

Are suspended art. 5 (definition of PE), art. 6 to 22 (allocation of taxing capacity), art. 24 (non-discrimination) and art. 27 (assistance in the collection of taxes).

Clearly, this unilateral suspension violates international law… But does the Russian President really care?

André Bailleux