Treaty between Russia and Cyprus – Russian MoF clarifies dual tax residence status of individuals

The Russian Ministry of Finance provides guidance on the dual tax residency status of individual tax payers.

In line with the letter No. 03-04-06/33393, dated 17 May 2018, guidance is provided by the Ministry of Finance (MoF) regarding cases of tax payers being dual tax residents of Russia and Cyprus.

It is clarified from the Russian authorities that if a Russian resident provides the Russian tax authorities with a certificate of tax residence issued by the Tax Department of Cyprus, such tax payer does not automatically lose the status of a Russian tax resident.

In such case, the individual tax payer is regarded as a dual tax resident of both states. For tax treaty purposes the resident status will be determined in accordance with the criteria provided in paragraph 2 of article 4 of the Cyprus – Russia Income and Capital Tax Treaty (1998) (as amended).