Relief at source - eligibility, documentation, deadlines - Russian debt securities

02.02.2021

Who can obtain relief at source?

Relief at source of withholding tax on dividends is available through Clearstream Banking for beneficial owners as follows:

Eligible beneficial ownersRate applicable at source

Residents of Double Taxation Treaty (DTT) countries

DTT rate

Tax exempt entities recognised by Russian law

0%

Russian legal entities

0%a

Russian individuals

15%b from 1 January 2021 

Non-resident legal entities

15% / 20%c

Non-resident legal entities with the dedicated article from Tax Code

0%d

a. According to the Russian Tax Code the Tax Identification number must be provided in case a Russian legal entity is eligible for exemption.
b. 13% until 31 December 2020.
c. Non-resident legal entities disclosing their legal status and residency are eligible for a reduced tax rate of 20% at source on interest from corporate bonds and 15% on mortgage-backed bonds.
Non-resident legal entities are furthermore eligible for 15% on interest from RUB-denominated corporate bonds issued in the period from 1 January 2017 to 31 December 2021, if providing the applicable NSD Tax codes.
d. Non-resident legal entities are eligible to 0% on Government bonds and Municipal bonds if providing the applicable article from the Tax Code justifying this exemption

Documentation requirements

All customers holding Russian corporate bonds or mortgage-backed bonds and applying for a reduced tax rate must submit:

Deadlines for receipt of documents

The One-Time Certificate for relief at source of withholding tax on interest from Russian Government bonds, Municipal bonds, corporate bonds and mortgage-backed bonds must be received by Clearstream Banking at the latest on the record date, by 16:00 CET.

The Breakdown of Holdings must be received by Clearstream Banking at the latest on the record date by 16:00 CET.