Tax Messenger
The State Duma has passed a law on the ratification of the double taxation treaty between Russia and the UAE in the third reading
25.06.2025
On 24 June, the State Duma of the RF passed a law on the ratification of the Double Taxation Treaty between Russia and the UAE ("DTT") in the third reading. Further steps required for the DTT to be ratified include approval by the Federation Council, signature by the President of Russia and official publication.
Article 31 of the DTT lays down the following procedure for the entry into force of the Treaty:
"1. Each of the Contracting States shall notify the other in writing, through diplomatic channels, of the completion of the procedures required by its law for the entry into force of this Agreement. This Agreement shall enter into force on the date of the later of these notifications and shall apply:
- with regard to taxes withheld at source, in respect of amounts paid or credited on or after 1 January of the calendar year following the year in which this Agreement enters into force and in subsequent years, and
- with regard to other taxes on income, in respect of tax periods beginning on or after January 1 of the calendar year following the year in which this Agreement enters into force and in subsequent years."
Thus, if Russia and the UAE complete the relevant procedures for the ratification of the Treaty which are laid down in their national laws and exchange written notifications on the completion of domestic procedures by the end of 2025, then the DTT between Russia and the UAE will enter into force on 1 January 2026. Later completion of legislative procedures would postpone the entry into force of the DTT by a calendar year. At the same time, the DTT between Russia and the UAE dated 7 December 2011 (which covers a limited range of persons) will cease to be effective from the date of entry into force of the new DTT (paragraph 2 of Article 31 of the DTT).
We will monitor further developments.
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Vladimir Zheltonogov
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