List of foreign countries’ competent authorities authorized
to issue tax residency certificates for the purposes
of article 312 of the Russian Tax Code
Note:
This List is based on the provisions of the effective double tax treaties of the Russian Federation,
clarifications given by regulatory authorities, and Russian arbitrazh courts’ rulings.
Please note that the competent authorities directly named in the relevant treaties are in most cases
authorized to delegate their authority to other persons or bodies. Therefore, where a certificate is received
from a foreign country’s body not included on this List, information on such body’s authority can be inquired
from the Federal Tax Service of Russia (Russian Ministry of Finance’s Letter No. 03-08-13 dated 22 May 2009).
Country
Australia
Competent Authority
The Commissioner of Taxation or his authorized
representative
Austria
The Federal Minister of Finance or his authorized
representative. In particular, a local tax office
may act as an authorized representative (Ruling
No. КА-А41/6518-11 of the Federal Arbitrazh
Court of the Moscow District, dated 7 July 2011)
Azerbaijan
The Ministry of Finance or its authorized
representative
Albania
The Minister of Finance or his authorized
representative
Algeria
The Ministry of Finance or its authorized
representative
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
Australia for the avoidance of
double taxation and the prevention
of fiscal evasion with respect to
taxes on income dated 7 September
2000
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Austria for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 13 April 2000
Subparagraph (f) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Azerbaijan for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 3 July 1997
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Albania for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 11 April 1995
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Democratic People's Republic of
Algeria for the avoidance of double
taxation with respect to taxes on
income and capital dated 10 March
2006
Country
Argentina
Armenia
Belarus
Competent Authority
The Ministry of Economy, Works and Public
Services, Secretary
of Public Revenue (el Ministerio de Economía y
Obras y Servicios Públicos, Secretaría de Ingresos
Públicos)
Basis
Subparagraph (j) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Argentina for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 10 October 2001
The tax inspectorate of the Republic of Armenia
Subparagraph (g) of paragraph 1 of
or its authorized representative <1>
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Armenia for the
avoidance of double taxation with
respect to taxes on income and
capital dated 28 December 1996
The Main State Tax Inspectorate or its authorized Subparagraph (i) of paragraph 1 of
representative.
article 3 of the Agreement between
City (or district) tax inspectorates of the Ministry the Government of the Russian
of Taxes of the Republic of Belarus (at the
Federation and the Government of
location of the relevant organizations) are
the Republic of Belarus for the
authorized to certify the domicile of residents of avoidance of double taxation and
the Republic of Belarus. Such certifications must the prevention of fiscal evasion with
be signed by the head (or a deputy head) of the
respect to taxes on income and on
relevant inspectorate and stamped with the
capital dated 21 April 1995
official seal bearing the inspectorate’s name
(Russian Federal Tax Service’s Letter No. ГИ-626/636@ dated 8 August 2007)
Belgium
The Minister of Finance or his authorized
representative
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Belgium for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 16 June 1995
Bulgaria
The Minister of Finance or his authorized
representative.
In particular, the Tax Administration, the unit of
the Ministry of Finance, is such authorized
representative. Therefore, certificates may be
issued by local tax authorities.
(Ruling No. А33-18853/03-С3-Ф02-4672/04-С1 of
the Federal Arbitrazh Court of the East Siberian
District, dated 16 November 2004)
Subparagraph (g) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Bulgaria for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 8 June 1993
Country
Botswana
Competent Authority
The Minister of Finance and
Development Planning, represented by the
Commissioner of Taxes
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Botswana for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 8
April 2003
Brazil
The Minister of Finance, the Secretary of Federal
Revenue or their authorized representatives
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Federative Republic of Brazil for
the avoidance of double taxation
and the prevention of fiscal evasion
with respect to taxes on income
dated 22 November 2004
United Kingdom
The Commissioners of Inland Revenue or their
authorised representative <2>.
In its Ruling No. А40-151888/10-129-621 dated
14 October 2011, the Federal Arbitrazh Court of
the Moscow District ruled that a residency
certificate issued by a tax inspector of the HM
Revenue & Customs was a proper certification.
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the United Kingdom of Great Britain
and Northern Ireland for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and
capital gains dated 15 February
1994
Hungary
The Minister of Finance or his authorised
representative.
In particular, the Tax and Financial Control
Administration is such authorized representative
(Ruling No. N А55-3204/2004-43 of the Federal
Arbitrazh Court of the Volga District, dated 5
October 2004)
Venezuela
The Integrated National Service of Tax and
Customs Administration (Servicio Nacional
Integrado de Administracion Aduanera y
Tributaria — SENIAT), or its authorized
representative
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Hungary for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 1 April 1994
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and
the Government of the Bolivarian
Republic of Venezuela for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 22 December 2003
Country
Vietnam
Competent Authority
The Minister of Finance or his authorized
representative
Basis
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Socialist Republic of Vietnam for
the avoidance of double taxation
and the prevention of fiscal evasion
with respect to taxes on income
dated 27 May 1993
Germany
The Federal Ministry of Finance or the agency to
which it has delegated its powers.
In particular, certificates may be issued by local
agencies in charge of finance or taxes (Russian
Ministry of Finance’s Letter No. 03-08-07 dated 6
April 2005; Ruling No. А68-1047/08-47/12 of the
Federal Arbitrazh Court of the Central District
dated 20 September 2011; and Ruling No. А56281/2007 of the Federal Arbitrazh Court of the
North-West District dated 11 March 2008)
The Minister of Finance or his authorized
representative
Subparagraph (f) of paragraph 1 of
article 3 of the Convention between
the Russian Federation and the
Federal Republic of Germany for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 29 May 1996 (as
amended on 15 October 2007)
Greece
Denmark
The Minister for Taxation or his authorized
representative
Egypt
The Minister of Finance or his authorized
representative
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Hellenic Republic for the
avoidance of double taxation and
for the prevention of fiscal evasion
with respect to taxes on income and
on capital dated 26 June 2000
Subparagraph (f) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Denmark for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 8 February 1996
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Arab Republic of Egypt for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 23 September 1997
Country
Competent Authority
The Minister of Finance or his authorized
representative
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the State of Israel for the avoidance
of double taxation and for the
prevention of fiscal evasion with
respect to taxes on income dated 25
April 1994
India
The Central Government in the Ministry of
Finance (Department of Revenue) or its
authorized representative
Indonesia
The Minister of Finance or his authorized
representative
Iran
The Minister of Economic Affairs and Finance or
his authorized representative
Subparagraph (k) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of India for the
avoidance of double taxation with
respect to taxes on income dated 25
March 1997
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Indonesia for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 12
March 1999
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Islamic Republic of Iran for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 6 March 1998
Ireland
The Internal Revenue Service or its authorised
representative
Iceland
The Minister of Finance or his authorized
representative
Israel
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
Ireland and for the avoidance of
double taxation with respect to
taxes on income dated 29 April
1994
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Iceland for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 26
November 1999.
Spain
Country
Competent Authority
The Minister of Economy and Finance or its
authorized representative
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Spain for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 16 December 1998
Italy
The Ministry of Economy and Finance <3>
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Italian Republic for the
avoidance of double taxation with
respect to taxes on income and on
capital and the prevention of fiscal
evasion dated 9 April 1996
Kazakhstan
The Ministry of Finance or its authorized
representative
Canada
The Minister of National Revenue or his
authorized representative
Qatar
The Minister of Finance, Economy and Trade or
his authorised representative
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Kazakhstan for the
avoidance of double taxation and
prevention of fiscal evasion with
regard to taxes on income and
capital dated 18 October 1996
Subparagraph (f) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
Canada for the avoidance of double
taxation and the prevention of fiscal
evasion with respect to taxes on
income and on capital dated 5
October 1995
Subparagraph (j) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the State of Qatar for the avoidance
of double taxation with respect to
taxes on income dated 20 April
1998
Country
Cyprus
Kyrgyzstan
Competent Authority
The Minister of Finance or his authorised
representative.
A list of authorized representative is set out in
Russian Ministry of Finance’s Letter No. 03-08-13
dated 17 June 2010. According the said Letter,
authorized representatives are:
- The Director of the Inland Revenue Department
of the Ministry of Finance (see also Ruling No.
14977/09 of the Presidium of the Supreme
Arbitrazh Court of the Russian Federation dated 6
April 2010); and
- Revenue officers in Nicosia, Limassol and
Larnaca districts.
The Ministry of Finance or its authorized
representative
China
The State Administration of Taxation or its
authorised representatives
North Korea
The Ministry of Finance or its authorized
representative
South Korea
The Minister of Finance or his authorized
representative
Cuba
The Minister of Finance and Prices or his
authorized representative
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Cyprus for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 5 December 1998
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of the Kyrgyzstan for
the avoidance of double taxation
and the prevention of fiscal evasion
with respect to taxes on income
dated 13 January 1999
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the People's Republic of China for
the avoidance of double taxation
and
the prevention of fiscal evasion with
respect to taxes on income dated 27
May 1994
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Democratic People's Republic of
Korea
for the avoidance of double taxation
with respect to taxes on income and
on capital dated 26 September 1997
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Korea for the
avoidance of double taxation with
respect to taxes on income dated 19
November 1992
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Cuba for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 14 December 2000
Country
Kuwait
Competent Authority
The Minister of Finance or his authorized
representative
Latvia
The Ministry of Finance or its authorized
representative
Lebanon
The Minister of Finance or his authorized
representative
Lithuania
The Ministry of Finance or its authorized
representative.
In particular, local offices of the State Tax
Inspectorate under the Ministry of Finance are
such authorized representatives (Ruling No. А218812/2009 of the Federal Arbitrazh Court of the
North West District dated 14 March 2011).
Luxembourg
The Minister of Finance or his authorized
representative.
In particular, the Direct Taxation Authority of the
Grand Duchy of Luxembourg (Administration des
contributions directes du Grand-Duché de
Luxembourg) is such authorized representative
(Ruling No. 7038/03 of the Presidium of the
Supreme Arbitrazh Court of the Russian
Federation dated 16 December 2003; and Ruling
No. А48-2871/08-18 of the Federal Arbitrazh
Court of the Central District dated 27 August
2009)
The Ministry of Finance or its authorized
representative
Macedonia
Basis
Subparagraph (j) of paragraph 1 of
article 3 of the Agreement between
the Russian Federation and the
State of Kuwait for the avoidance of
double taxation and the prevention
of fiscal evasion with respect to
taxes on income and on capital
dated 9 February 1999
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Latvia for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 20 December 2010
Subparagraph (k) of paragraph 1 of
article 3 of the convention between
the Government of the Russian
Federation and the Government of
the Lebanese Republic for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 8
April 1997
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Lithuania for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 29 June 1999
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Russian Federation and the
Grand Duchy of Luxembourg for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and
capital dated 28 June 1993
Subparagraph 7 of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Macedonia for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 21 October 1997
Country
Malaysia
Competent Authority
The Minister of Finance or his authorized
representative
Mali
The Ministry of Finance or its authorized
representative
Morocco
The Minister of Finance or his authorized
representative
Mexico
The Ministry of Finance and Public Credit
Moldova
The Ministry of Finance or its authorized
representative
Mongolia
The Minister of Finance or his authorized
representative
Basis
Subparagraph (d) of paragraph 1 of
article 3 of the Agreement between
the Government of the Union of
Soviet Socialist Republics and the
Government of Malaysia for the
avoidance of double taxation with
respect to taxes on income dated 31
July 1987
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Mali for the
avoidance of double taxation and
establishment of the rules of mutual
assistance with respect to taxes on
income and on capital dated 25
June 1996
Subparagraph (g) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Kingdom of Morocco for the
avoidance of double taxation with
respect to taxes on income and
capital dated 4 September 1997
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the United Mexican States for the
avoidance of double taxation with
respect to taxes on income dated 7
June 2004
Subparagraph (e) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Moldova for the
avoidance of double taxation with
respect to taxes on income and on
capital and the prevention of fiscal
evasion dated 12 April 1996
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
Mongolia for the avoidance of
double taxation with respect to
taxes on income and capital dated 5
April 1995
Country
Namibia
Competent Authority
Permanent Secretary of the Ministry of Finance,
being the Chief Director and Administrator in the
field of the Tax Laws of Namibia, or his
authorized representative
Netherlands
The Minister of Finance or his duly authorised
representative.
In particular, local tax authorities are such
authorized representatives (Ruling No. А565071/2007 of the Federal Arbitrazh Court of the
North West District, dated 22 August 2007).
According to the clarifications given by the
Ministry of Finance of the Kingdom of the
Netherlands, certificates issued and signed by
local tax officers shall be submitted for
legalization to the Tax Administration of the
Ministry of Finance of the Kingdom of the
Netherlands (Russian Ministry of Finance’s Letter
No. 03-08-07 dated 6 April 2005).
New Zealand
The Commissioner of Inland Revenue or his
authorized representative
Norway
The Minister of Finance and Customs or his
authorized representative.
In particular, the Tax Administration of Norway
and local tax authorities are such authorized
representatives (Ruling No. А56-5119/2008 of
the Federal Arbitrazh Court of the North West
District, dated 30 October 2008, upheld by the
Supreme Arbitrazh Court of the Russian
Federation (Ruling No. 2157/09 dated 5 March
2009))
The Minister of Finance or his authorized
representative.
In particular, treasury offices of the Republic of
Poland are such authorized representatives
(Ruling No. Ф08-8180/07-3056А of the Federal
Arbitrazh Court of the North Caucasian District,
dated 12 December 2007, upheld by the
Supreme Arbitrazh Court of the Russian
Federation (Ruling No. 4107/08 dated 2 April
2008))
Poland
Basis
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Namibia for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 31
March 1998
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Kingdom of the Netherlands for
the avoidance of double taxation
and the prevention of fiscal evasion
with respect to taxes on income and
on property dated 16 December
1996
Subparagraph (c) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
New Zealand for the avoidance of
double taxation and the prevention
of fiscal evasion with respect to
taxes on income dated 5 September
2000
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Kingdom of
Norway for the avoidance of double
taxation and the prevention of fiscal
evasion with respect to taxes on
income and on capital dated 26
March 1996
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Poland for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 22 May 1992
Country
Portugal
Competent Authority
The Minister of Finance, the Director General of
Taxation or their authorized representatives
Basis
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Portuguese Republic for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 29
May 2000
Romania
The Ministry of Finance or its authorized
representative
Saudi Arabia
The Ministry of Finance represented by the
Minister of Finance or his authorised
representative
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
Romania for the avoidance of
double taxation with respect to
taxes on income and on capital
dated 27 September 1993
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Saudi Arabia
for the avoidance of double taxation
and the prevention of tax evasion
with respect to taxes on income and
on capital dated 11 February 2007
Singapore
The Minister of Finance or his authorized
representative
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Singapore for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 9
September 2002
Syria
The Minister of Finance of the Syrian Arab
Republic or his authorized representative
Slovakia
The Minister of Finance of the Slovak Republic or
his authorized representative
Subparagraph (j) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Syrian Arab Republic for the
avoidance of double taxation with
respect to taxes on income dated 17
September 2000
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Slovak Republic for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 24 June 1994
Country
Slovenia
USA
Tajikistan
Thailand
Competent Authority
The Ministry of Finance or its authorized
representative
Basis
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Slovenia for the
avoidance of double taxation with
respect to taxes on income and
capital dated 29 September 1995
The Secretary of the Treasury or his delegate.
Subparagraph (h) of paragraph 1 of
Such delegates are the U.S. Internal Revenue
article 3 of the Convention between
Service and its regional offices (Russian Ministry
the Russian Federation and the
of Finance’s Letters No. 03-08-05 dated 15 June
United States of America for the
2012, No. 03-08-05/2 dated 2 February 2011, and avoidance of double taxation and
No. 03-08-05/1 dated 1 April 2010; Russian
the prevention of fiscal evasion with
Federal Tax Service’s Letter No. 26-2-08/5988
respect to taxes on income and
dated 12 May 2005; and Ruling No. 5317/11 of
capital dated 17 June 1992
the Presidium of the Supreme Arbitrazh Court of
the Russian Federation dated 20 September
2011).
The Ministry of Finance or its authorized
Subparagraph (k) of paragraph 1 of
representative
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Tajikistan for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 31 March 1997
The Minister of Finance or his authorized
Subparagraph (j) of paragraph 1 of
representative
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Thailand for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 23
September 1999
Turkmenistan
Ministry of Economy and Finance and the Main
State Tax Service of Turkmenistan or their
authorized representative
Turkey
The Ministry of Finance or its authorized
representative.
In particular, the Tax Inspection Board of the
Ministry of Finance and local tax authorities are
such authorized representatives (Ruling No. А569042/2006 of the Federal Arbitrazh Court of the
North West District, dated 19 March 2007)
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
Turkmenistan for the avoidance of
double taxation with respect to
taxes on income and capital dated
14 January 1998
Subparagraph (i) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Turkey for the
avoidance of double taxation with
respect to taxes on income dated 15
December 1997
Country
Uzbekistan
Competent Authority
The State Tax Committee of the Republic of
Uzbekistan
Ukraine
The Ministry of Finance or its authorized
representative
Philippines
The Minister of Finance or his authorized
representative
Finland
The Ministry of Finance or the Ministry's
authorized representative or the authority which
is designated as competent authority by the
Ministry.
In particular, tax authorities of Finland are
authorized to issue certificates
(Rulings issued by the Federal Arbitrazh Court of
the North-West District: No. А56-7553/2010
dated 22 November 2010, and No. А269060/2009 dated 24 May 2010 (upheld by the
Supreme Arbitrazh Court of the Russian
Federation, Ruling No. ВАС-13041/10 dated 23
September 2010)
France
The Minister in charge of the Budget or his
authorized representative.
In particular, the Main Tax Administration of
France is such authorized representative (Russian
Ministry of Finance’s Letter No. 03-08-05/1 dated
9 October 2008; Ruling No. Ф08-738/2007-328А
of the Federal Arbitrazh Court of the North
Caucasian District, dated 5 March 2007)
Basis
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of Uzbekistan for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 2 March 1994
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
Ukraine for the avoidance of double
taxation with respect to taxes on
income and on capital and the
prevention of fiscal evasion dated 8
February 1995
Subparagraph (h) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of the Philippines for
the avoidance of double taxation
and the prevention of fiscal evasion
with respect to taxes on income
dated 26 April 1995
Subparagraph (g) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Finland for the
avoidance of double taxation with
respect to taxes on income dated 4
May 1996 (as amended on 14 April
2000)
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Republic of France for the
avoidance of double taxation and
the prevention of fiscal evasion and
fraud with respect to taxes on
income and on capital dated 26
November 1996
Country
Croatia
Competent Authority
The Minister of Finance or his authorized
representative
Czech Republic
The Minister of Finance or his authorized
representative
Switzerland
The Director of the Federal Tax Administration or
his authorized representative.
In particular, cantonal tax administrations are
such authorized representatives (Ruling No. А2710300/2010 of the Federal Arbitrazh Court of the
West Siberian District, dated 17 May 2011)
Sweden
The Minister of Finance, his authorized
representative or the authority which is
designated as a competent authority for the
purposes of the Convention.
In particular, the Swedish Tax Agency is such
competent authority (Ruling No. А56-22691/2008
of the Federal Arbitrazh Court of the North West
District, dated 30 July 2009)
The Commissioner General of Inland Revenue
Subparagraph (g) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Kingdom of Sweden for the
avoidance of double taxation with
respect to taxes on income dated 15
June 1993
Subparagraph (j) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Democratic Socialist Republic of
Sri Lanka for the avoidance of
double taxation and the prevention
of fiscal evasion with respect to
taxes on income dated 2 March
1999
South Africa
The Commissioner for Inland Revenue or his
authorized representative
Subparagraph (g) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of South Africa for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income dated 27
November 1995
Yugoslavia
(Serbia and
Montenegro)
The Union’s Finance Ministry <4> or its
authorized representative
Subparagraph 9 of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
Sri-Lanka
Basis
Subparagraph (j) of paragraph 1 of
article 3 of the Agreement between
the Government of the Russian
Federation and the Government of
the Republic of Croatia for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 2 October 1995
Subparagraph (i) of paragraph 1 of
article 3 of the Convention between
the Government of the Russian
Federation and the Government of
the Czech Republic for the
avoidance of double taxation and
the prevention of fiscal evasion with
respect to taxes on income and on
capital dated 17 November 1995
Subparagraph (h) of paragraph 1 of
article 3 of the Agreement between
the Russian Federation and the
Swiss Confederation for the
avoidance of double taxation with
respect to taxes on income and on
capital dated 15 November 1995
Country
Japan
Competent Authority
The Minister of Finance or his authorized
representative.
In particular, the National Tax Agency of Japan is
such authorized representative (Ruling No. Ф03А59/08-2/1101 of the Federal Arbitrazh Court of
the Far Eastern District, dated 21 April 2008)
Basis
the Federal Republic of Yugoslavia
for the avoidance of double taxation
with respect to taxes on income and
capital dated 12 October 1995
Subparagraph (d) of article 3 of the
Convention between the
Government of the Union of Soviet
Socialist Republics and the
Government of Japan for the
avoidance of double taxation with
respect to taxes on income dated 18
January 1986
<1> Article 2 of the Protocol dated 24 October 2011 amends article 3 of the Agreement. Upon the entry of
the said Protocol into force, the competent authorities of the Republic of Armenia will be the Ministry of Finance
of the Republic of Armenia and the State Revenue Committee of the Government of the Republic of Armenia, or
their authorized representatives.
<2> Currently, the HM Revenue & Customs formed in April 2005 by the merger of the Inland Revenue and
Her Majesty’s Customs and Excise shall be treated as the competent authority (see also Russian Ministry of
Finance’s Letter No. 03-08-05/1 dated 12 April 2012).
<3> Before 1 June 2012, the competent authority of Italy was the Ministry of Finance (subparagraph (i) of
paragraph 1 of article 3 of the Convention; articles II and IV of the Protocol dated 13 June 2009; Russian Federal
Tax Service’s Letter No. ЕД-4-3/8942@ dated 31 May 2012; and Russian Ministry of Finance’s Letter No. 03-08-13
dated 17 May 2012).
<4> The independent Republic of Serbia and Republic of Montenegro are legal successors to Yugoslavia as
party to the Convention (Russian Federal Tax Service’s Letter No. ГИ-6-26/635@ dated 8 August 2007). We,
therefore, believe that the competent authorities authorized to issue tax residency certificates in Serbia and
Montenegro are the Ministry of Finance of the Republic of Serbia and the Ministry of Finance of the Republic of
Montenegro, respectively, or their authorized representatives.
Tax Guidebook. The Practical Guide on Income Tax {ConsultantPlus Computer-Based Legal Research System}