Italy – Russia Tax Treaty
The Italy-Russia tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, and interest at 10%. Royalties are taxed at a uniform 0% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in Italy's network and one of 27 in Russia's. The general dividend rate of 10% compares to a median of 15% across Italy's network and 10% across Russia's.
Verified data
FNS International Tax Treaties (nalog.gov.ru) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Note: treaties with US, UK, and CA suspended effective 2022-2023.)
Withholding Rate Summary
Source: Russia Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Russia) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 5% | 15% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 10% | 15% |
| Interest Bank interest, bonds, loans | 10%saves 10% | 20% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 0% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Russia)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 15%.
Source: Russia Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 20% statutory rate. This represents a 10% reduction from the statutory rate.
Source: Russia Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 0% to 0%.
Source: Russia Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Russia Treaty Reference
Comparative Context
🇮🇹Italy's Network
Among Italy's 47 active treaty partners, the 10% general dividend rate ranks 7th (median: 15%).
| Partner | Rate |
|---|---|
| Hungary | 10% |
| Poland | 10% |
| Romania | 10% |
| Russia (this treaty) | 10% |
| Saudi Arabia | 10% |
| Austria | 15% |
| Australia | 15% |
🇷🇺Russia's Network
Among Russia's 27 active treaty partners, the 10% general dividend rate ranks 9th (median: 10%).
| Partner | Rate |
|---|---|
| Denmark | 10% |
| Hungary | 10% |
| India | 10% |
| Italy (this treaty) | 10% |
| South Korea | 10% |
| Norway | 10% |
| Poland | 10% |