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THE NETWORK OF RUSSIAN DOUBLE
TAXATION CONVENTIONS: OPPORTUNITIES FOR INVESTMENTS. Danil V. Vinnitskiy
1. Introduction.
During the last 19 years, the Russian Federation (the RF, Russia) has pursued quite an active international fiscal policy; it has signed 85 conventions for the avoidance of double taxation with respect to taxes on income and capital. At present, Russia has 77 double taxation conventions (DTCs) in force; besides, 8 DTCs have been negotiated and signed but not ratified by the RF Parliament.
Russian DTCs generally follow the 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 February 24, 2010 No.84. The difference between the Regulation and the OECD model is not significant. For instance, one of the most remarkable points is that the RF model provides for less favorable conditions for at-
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