Применение российских соглашений об избежании двойного налогообложения с КНР и Гонконгом

Abstract

The strengthening of interstate partnership between Russia and China inevitably affects the expansion of international cooperation between the business of the two countries. In this regard, we can detect both previously repeatedly encountered and new problems in the application of double taxation treaties with the PRC (2014) and Hong Kong (2016). Based on the results of the study of law enforcement practice, the main legal problems are traced that are relevant today for Russian and Chinese companies when doing business, creating joint ventures and other forms of economic cooperation. It is concluded that the actual possibilities for justifying the application of a reduced 5% rate based on the Double taxation treaty with the PRC are largely limited. It is all because of the conditions of unprecedented sanctions pressure on the Russian economy and the inevitable reaction of Chinese banks which are forced to refuse to open special accounts for depositing authorised capital to Russian companies and citizens. Despite this, the friendly Chinese jurisdiction allows to achieve the main tasks facing Russian and international business.