Complete Suspension of the DTT Between Russia and Germany From 1 January 2027

02.09.2026
From 01.01.2027, Germany will completely suspend the application of all articles of the Double Taxation Treaty (DTT) with Russia. It should be noted that the DTT had been partially suspended unilaterally by Russia from 08.08.2023, whilst some of its articles on the avoidance of double taxation remained in force. The DTT is now completely suspended for Russia as well. Although it had effectively not been applied in Germany since 01.01.2024, its full official suspension is bad news for all individual taxpayers in both Russia and Germany. The main obvious consequence of this termination is the burden of double taxation arising from the inability to claim a credit for personal income tax already paid. That said, Russian companies will likely be able to avoid double taxation of profits on the basis of the direct provisions of the Tax Code of the Russian Federation (TC RF).

How we can help

As always, tax implications and recommendations for each taxpayer will depend on the specific facts of their business activities and circumstances. Our professional Tax Team analyses each specific situation and develops a step-by-step action plan to minimise the negative consequences of the DTT suspension pursuant to the TC RF. We also engage our partners – professional tax advisers and lawyers in Germany – to assess the implications and prepare recommendations under German tax law for our clients.