In this letter, the Federal Tax Service officially explained and listed the agreements to which the simplified provision on the benefits limitation applies. It notes that, taking into account Decree No. 585, dated August 08, 2023 the simplified provision on benefits limitation will apply only to unsuspended DTTs (these are DTTs concluded with the Republic of India, the Republic of Kazakhstan, the Republic of Chile as well as, from January 01, 2025, with the United Mexican States).

Document: Letter of the Federal Tax Service of Russia dated August 06, 2024 N ШЮ-4-13/8897@ “On the procedure for applying the DDTs”.

The Federal Tax Service has provided clarifications on the application of a simplified provision on the benefits limitation in relation to certain double taxation treaties (DTTs).