Treaty detail
United States - Russia tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1992-06-17
Effective
1994-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 5%
The 5 percent corporate rate has historically depended on direct ownership of at least 10 percent of the voting stock of the dividend payer. In April 2024 the United States suspended treaty benefits with Russia, so any current claim requires very careful, situation-specific review of suspension scope and effective dates.
Interest
Rate: 0%
IRS Treaty Table 1 historically reflects a zero-percent result for qualifying interest. Suspension of benefits in 2024 means real-world reliance on this rate cannot be assumed and primary-source analysis is required.
Royalties
Rate: 0%
The treaty historically removed source-country withholding on most royalty categories, but ongoing suspension of benefits complicates current reliance and the article text must be reviewed in context.
Permanent establishment
Construction threshold: more than 18 months
Dependent-agent analysis remains relevant under the treaty wording, but current reliance is complicated by the U.S. suspension of treaty benefits effective in 2024.
Other treaty flags
Pension treatment generally followed a residence-state framework, but the 2024 suspension of treaty benefits means current outcomes should not be assumed from the historical text alone.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to any claim for reduced withholding or business-profit protection.
The residence article is especially important here because U.S. and Russian domestic residence rules can both reach the same taxpayer. With benefits suspended as of April 2024, residence analysis cannot be the only step in claiming treaty relief.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
The treaty generally follows an OECD-style PE construction with an 18-month construction-and-installation threshold. The dependent-agent rules and preparatory-activity carve-outs still require article-level review, and current applicability is constrained by the 2024 suspension.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
This is the operating rule founders and consultants typically rely on after a PE analysis. With benefits suspended, real-world reliance on Article 7 protection requires careful, case-specific analysis rather than treaty-table shortcuts.
Article 10
Dividends
Provides treaty limits on source-country dividend withholding in qualifying cases.
The dividend article historically capped source-country withholding at 5 percent for qualifying corporate shareholders and 10 percent otherwise. The April 2024 U.S. suspension of treaty benefits materially affects current claims, so primary-source review is essential.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Interest was historically one of the clearest treaty benefits in this agreement. After the 2024 suspension, claiming the zero-percent rate is no longer routine and documentation, beneficial-ownership, and effective-date analysis all matter more than usual.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article historically supported a zero-percent outcome across major categories. With benefits suspended, taxpayers should expect that source-country withholding may revert to domestic-law rates until the treaty status changes.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Russia treaty documents pageVerified 2026-05-20
- Official U.S.-Russia treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
- Treasury announcement on suspension of tax treaty benefits with RussiaVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.