Соглашение об избежании двойного налогообложения: Гонконг — Россия: ответы с источниками

01.01.2017 в России, с года налогообложения 2017/18 в Гонконге; в силе с 29.07.2016

«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»

Источник: ird.gov.hk · копия источника от 2026-10-03

«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

01.01.2017 в России

с года налогообложения 2017/18 в Гонконге

«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»

Источник: ird.gov.hk · копия источника от 2026-10-03

«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

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«n or assignment.] Article 11 Interest 1. Interest arising in a Contracting Party and paid to a resident of the other Contracting Party shall be taxable only by that other Party. 2. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. 3. The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the interest arises, through a permanent establishment situated therein, or performs in that other Party independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«cle 13 of this Agreement: ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision) Notwithstanding any provisions of this Agreement, a benefit under the Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Agreement. 30 Article 27 Anti-Abuse Measures Nothing in this Agreement shall prejudice the right of each Contracting Party to apply its internal laws and measures concerning tax avoidance, whether or not described as such. Article 28 Entry into For»

Источник: ird.gov.hk · копия источника от 2026-10-03