The main issue in the Protocol to the DTT with Switzerland is that there are new terms regarding information exchange. These terms cover issues with regard to both the taxes within the scope of the DTT (taxes on income, capital gains, and property) and, moreover, with regard to indirect taxes (VAT and excise duty among them).
In accordance with the Protocol, a tax authority must not provide another party to which the DTT applies with information which discloses a trade, business, industrial, commercial or professional secret. But this rule does not cover bank secrecy, so Swiss banks, which are famous for their level of information safety, must disclose information about their clients at the request of tax authorities. Even when the tax authority does not need information for its own purposes, it cannot refuse to change that information.
The DTT with Argentina is based on the OECD Model Convention. The main issue is the rates of taxes on dividends, royalty and interest. The general rate of withholding tax on dividends is 15%, but if an entity is a beneficial owner of more than 25% of shares, the rate will be 10%. Interest as well as royalties may be withheld, but if the recipient is a beneficial owner, the rate must not be more that 15%.
The DTT with Latvia is based on the OECD Model Convention too. The general rate of withholding tax on dividends is 10%, but if a shareholder is a legal entity (not a partnership) and the amount of the investment is more than USD 75,000, the rate is 5%. The general rate of taxation on interest is 10%, but if the loan is issued by a bank or other financial organization, the rate will be 5%. The general rate of taxation on royalties must not be more than 5% if a recipient is a beneficial owner.
The Protocol to the DTT with the Swiss should make taxpayers change some of their tax optimization schemes, but it is a positive development. It may be a useful instrument for Russian authorities to fight against tax avoidance and corruption.
The ratification of the DTTs with Latvia and Argentina is very useful: it will influence trade and economic connections between these countries and Russia.