November 3, 2015

The Russian Government recently published a Model Agreement on Exchange of Information on Tax Matters which will be used as the basis for the conclusion of bilateral agreements with offshore jurisdictions (the Russian Model TIEA). This is in line with the global trend towards tax transparency and increased exchanging of tax information between countries. The Russian Model TIEA is based on OECD standards (with certain amendments).

TIEAs differ in scope from the double tax treaties which are currently used by the Russian tax authorities as the main instrument for obtaining information for tax purposes from foreign countries. The publication of the Russian Model TIEA is a step towards effective exchange of information with non-treaty jurisdictions.

The Russian tax authorities are expected to take a particular interest in obtaining information concerning foreign entities which might be controlled by Russian taxpayers. In addition to the right to request certain tax information the Russian tax authorities are seeking the opportunity to take part in tax audits held by the competent authorities of parties to TIEAs.