On 8 August 2023, the President of the Russian Federation signed Decree No. 585, suspending specific provisions of Russia’s double taxation treaties with 38 states it designates as ‘unfriendly’, the countries that introduced sanctions following the invasion of Ukraine in February 2022. Ireland is one of those 38 states. This post sets out, with dates and sources, what the decree actually did, what has happened since, and what it means in 2026 for Irish-resident taxpayers and businesses with Russian connections.
Updated: July 2026.
What Decree No. 585 Suspended, and What It Did Not
The decree did not terminate or suspend the treaties in whole. It suspended the distributive provisions that allocate taxing rights and grant reduced rates, broadly the articles covering permanent establishment, business profits, income from immovable property, dividends, interest, royalties, capital gains and employment income, together with the non-discrimination provisions. According to professional analyses of the decree, this covers roughly 18 to 22 articles in each affected treaty. The measure took effect on 8 August 2023 and does not have retroactive effect, so amounts already taxed before that date are not recalculated (sources: DLA Piper, ALRUD, Forte Tax and Law, UNCTAD Investment Policy Monitor).
The decree does not suspend the treaty articles on the persons and taxes covered, the determination of residence, the elimination of double taxation, the mutual agreement procedure, or the exchange of information. One important caveat applies to the elimination-of-double-taxation article: it operates by reference to income covered by the treaty, so where the distributive article for a given type of income has been suspended, the corresponding relief mechanism no longer functions for that income on the Russian side (source: Forte Tax and Law; ALRUD).
Which Countries Are Affected, and a Correction
The decree names treaties with 38 states. These are Australia, Austria, Albania, Belgium, Bulgaria, the United Kingdom, Hungary, Germany, Greece, Denmark, Ireland, Iceland, Spain, Italy, Canada, Cyprus, South Korea, Lithuania, Luxembourg, North Macedonia, Malta, New Zealand, Norway, Poland, Portugal, Romania, Singapore, Slovakia, Slovenia, the United States, Finland, France, Croatia, Montenegro, the Czech Republic, Switzerland, Sweden and Japan (sources: UNCTAD Investment Policy Monitor; EPAM; tp-law status review, February 2025).
For clarity, Northern Ireland is part of the United Kingdom and is not a separate country. The United Kingdom and Ireland are two distinct treaty partners on the list, and Ireland here means the Republic of Ireland.
The Double Taxation Treaty Between Russia and Ireland
Russia and Ireland signed their treaty for the avoidance of double taxation on 29 April 1994. The taxes to which it applies are set out below.
| Ireland | Russia |
| income tax, corporation tax, capital gains tax | profits of enterprises and organisations, income of individuals |
The Position From the Irish Side in 2026
The suspension is a unilateral Russian measure. As at July 2026, Revenue continues to list the 1994 Ireland-Russia treaty on its double taxation treaties page, and Ireland has not published a reciprocal suspension or revocation of its side of the treaty. This contrasts with the United Kingdom, which legislated to give effect to a suspension of the UK-Russia convention in UK law from 6 April 2025, and the United States, which suspended the operation of key articles of its treaty with Russia from 16 August 2024 (sources: Revenue.ie; UK Parliament, draft Revocation Order 2025; US Treasury notice, EY and RSM alerts).
In practice this means two things. On the Russian side, because Russia has suspended the relevant distributive articles, Russian-source payments to Irish residents are subject to Russian domestic withholding rather than the reduced treaty rates. On the Irish side, Ireland’s own rules on relief for foreign tax continue to apply, so an Irish-resident taxpayer may still be able to claim credit for Russian tax suffered, subject to the ordinary conditions and limits in Irish law. The exact interaction is fact-specific, and affected taxpayers should take professional advice.
Withholding Rates Since the Suspension: Consequences for Businesses
Where treaty relief no longer applies, Russian domestic withholding rates apply to payments from Russia to non-residents. On current sources these are:
- dividends: 15 per cent, in place of the reduced treaty rates that previously ranged between 5 and 10 per cent depending on the shareholding;
- interest: 20 per cent for foreign companies, where many treaty situations had provided an exemption or a reduced rate;
- royalties: 20 per cent for foreign companies, again in place of reduced treaty treatment.
These are the standard Russian domestic non-treaty rates, cross-checked against more than one source (sources: PwC Worldwide Tax Summaries; Forte Tax and Law; sector commentary from lawyersrussia.com and Expat Focus). Note that this corrects the earlier version of this article, which stated 15 per cent for interest; the Russian domestic rate on interest paid to foreign companies is 20 per cent.
Consequences for Individuals, and What Changed in Russia in 2025
Individuals who are tax resident in one state and receive income from the other can face a heavier burden where the distributive article for that income has been suspended and treaty rate protection falls away. This post does not advise on Russian domestic filing obligations, which is a matter for Russian-qualified advisers.
An important update since this article was first published: Russia replaced its flat personal income tax with a progressive scale of 13, 15, 18, 20 and 22 per cent from 1 January 2025, with each rate applying to income above the relevant threshold. Russia also increased its corporate profits tax from 20 to 25 per cent from 2025 (sources: Office of the President of Russia; Schneider Group; Awara). This supersedes the ’13 to 15 per cent from 2024′ figure in the original version of this post.
The Wider EU Context
Separately from the Russian decree, the EU added Russia to its list of non-cooperative jurisdictions for tax purposes on 14 February 2023, with publication in the Official Journal on 21 February 2023. Russia remains on that list, which can trigger defensive tax measures in EU member states for certain dealings with Russian counterparties (sources: Council of the EU; White and Case; International Tax Review).
Which Treaty Provisions Remain in Force
The provisions that are not suspended by the decree, as currently understood, are:
- the articles on the persons and taxes covered;
- the rules for determining residence;
- the article on the elimination of double taxation, subject to the caveat above that it only operates for income still covered by a live distributive article;
- the mutual agreement procedure and the exchange of information.
The mutual agreement procedure exists to resolve disputes where two states seek to tax the same base, and the exchange of information supports tax control. In practice, cooperation between the Russian authorities and many of the 38 states has been curtailed since 2022, so how far these mechanisms operate in reality is uncertain.
What This Means for Founders Restructuring Internationally
Treaty disruption of this kind sometimes prompts internationally mobile founders to review where their holding and trading structures sit, and some choose to establish within the EU. Ireland is a common destination: it applies a 12.5 per cent rate to trading income, it is an English-speaking EU member state, and it retains a broad network of double taxation treaties. Founders weighing a move often start with our guide on opening a company in Ireland to relocate, and Ireland has also featured as a destination in adjacent developments such as Slovakia’s new financial transaction tax.
Chern and Co is a licensed Irish Trust and Company Service Provider (TCSP, authorisation APP/1211/2018). All onboarding is subject to sanctions screening and anti-money-laundering checks under our regulatory obligations, and we do not act where a client or structure is sanctioned. Nothing here is a route to circumventing sanctions or tax obligations. For those exploring a lawful EU base, our non-resident company formation service and tax registration with Revenue set out the practical steps. Russian-speaking founders can also read our dedicated Russian-language section on registering an Irish company.
Frequently Asked Questions
Is the Ireland-Russia double taxation treaty still in force?
The treaty has not been terminated. Russia unilaterally suspended most of its operative provisions for 38 states, including Ireland, by Decree No. 585 of 8 August 2023. As at July 2026, Ireland has not published a reciprocal suspension, and Revenue continues to list the 1994 treaty. In practice, treaty rate relief on Russian-source income no longer applies on the Russian side for the suspended income types (sources: Revenue.ie; DLA Piper; UNCTAD).
What Russian withholding rates apply since the suspension?
Where treaty relief no longer applies, Russian domestic rates apply: broadly 15 per cent on dividends and 20 per cent on interest and royalties paid to foreign companies. These replace the lower treaty rates that previously applied (sources: PwC Worldwide Tax Summaries; Forte Tax and Law).
Does the suspension affect Irish companies with Russian counterparties?
It can. Russian-source payments may now bear higher Russian withholding, and Russia’s presence on the EU list of non-cooperative jurisdictions can trigger defensive measures in EU states for certain transactions. Any dealings must also comply with the applicable EU and national sanctions regimes. The position is fact-specific and professional advice is recommended (sources: Council of the EU; White and Case).
Has Ireland suspended its side of the treaty like the UK did?
Not on the basis of published guidance as at July 2026. The United Kingdom legislated to suspend the UK-Russia convention in UK law from 6 April 2025, and the United States suspended key provisions from 16 August 2024, but no equivalent Irish instrument has been identified. Revenue’s treaty page for Russia remains live (sources: UK Parliament; US Treasury; Revenue.ie).
This article is general guidance and reflects the position as at July 2026. It is not legal or tax advice. Tax outcomes depend on individual circumstances and on rules that continue to change. Anyone with a structure or income affected by the treaty suspension should obtain professional advice, and any activity involving Russian counterparties must comply with the applicable sanctions regimes.
