For the recent fifteen years the Russian Federation (RF) has pursued quite an active international fiscal policy; it has signed eighty-
Russian DTCs generally follow the Organization for Economic Cooperation and Development (OECD) model; however, special Articles in certain treaties concluded by Russia can be found. In principle, the Russian approach to DTCs is reflected in the model treaty approved by the RF Government Regulation of 28 May 1992 no. 352. The difference between it and the OECD model is not significant. For instance, one of the most remarkable points is that the RF model provides for less favourable conditions for at-
The influence of the RF model treaty (reproduced nearly word for word in the CIS (Commonwealth of Independent States). Recommendation of 15 May 1992 'On unification of tax treaties') on Russian tax treaty policy is, however, quite limited. It is symptomatic that there are no bilateral tax treaties, concluded by Russia, containing Articles which follow the above-
It is important that the Roadmap for the accession of the RF to the OECD convention was adopted by the Council at its 1163rd session on 30 November 2007. The Roadmap stipulates the following:
(1) eliminating international double taxation on income and capital through complying with the key substantive conditions underlying the OECD Model Tax Convention;
(2) eliminating double taxation through ensuring the primacy of the arm's length principle;
(3) engaging in effective exchange of information;
(4) combating harmful tax practices.