US partially suspends tax treaty with Russia

The U.S. Treasury Department provided formal notification to Russian authorities that it’s partially suspending a tax treaty as relations between the two countries continue to worsen over two years into the war in Ukraine.  

The IRS issued Announcement 2024-26 on Friday providing notice of the partial suspension of the U.S.-Russia tax treaty. That came on the heels of an announcement Monday by the Treasury Department. 

The formal notice to the Russian Federation on June 17 confirms the suspension of the operation of paragraph 4 of Article 1 and Articles 5-21 and 23 of the Convention between the United States of America and the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, which was signed in Washington on June 17, 1992, as well as the operation of an accompanying Protocol, by mutual agreement. 

Russian officials had moved last year to suspend those agreements. The action by the U.S. Treasury responds to a notification by the Russian Federation on Aug. 8, 2023, of its desire to suspend paragraph 4 of Article 1 and Articles 5-21 and 23 of the Convention, as well as the Protocol.

The suspension will take effect both for taxes withheld at the source and with respect to other taxes on Aug. 16, 2024, and will continue until otherwise decided by the U.S. and Russian governments.