Foreign Tax Credit: Interim Results of the 2026 Tax Campaign
During the 2026 tax campaign, our team claimed foreign tax credits (withholding tax at source) for a significant number of clients. Although desk tax audits (in-house audits) are still ongoing for a number of cases, we consider it appropriate to summarize the interim results.
The approach taken by the tax authorities in completed audits generally aligns with the position set out in the Letter of the Federal Tax Service of Russia dated April 15, 2026 No. ШЮ-36-13/2999.
Key takeaways:
— Denounced DTTs (Netherlands, Ukraine, Latvia, Lithuania): foreign tax credit is not allowed.
— Fully suspended DTTs (Canada, Sweden, United Kingdom): foreign tax credit is not available.
— Partially suspended DTTs by both parties (France, Czech Republic, United States): credit is allowed without applying treaty limitations.
— Partially suspended DTTs by the Russian Federation: credit is allowed within the limits of the treaty rates.
We continue to support ongoing audits and will keep you informed of further developments.