The Russia–India treaty is active and has an unusual feature — a specific article covering technical-service fees that most treaties don't. Capturing the 10% rate, on dividends and on those fees, is the practical question.
An active treaty with 10% on dividends, and a distinct technical-services article that covers management and consulting fees at a defined rate — an edge others lack.
Claim the rate with a residency certificate and beneficial-ownership file, and use the technical-fees article properly rather than defaulting to domestic withholding.
Treaty overview: key rates
Dividends: applying the 10% rate
Fees for technical services: the India-specific advantage
Permanent establishment rules
Optimal holding structure for Indian companies in Russia
Practical compliance checklist
Russia and India signed their double tax treaty in 1997. Unlike most Western-country treaties — which Russia suspended in March 2023 — the Russia-India DTT remains fully in force as of 2026. For the growing community of Indian companies operating in Russia, the treaty provides significant relief compared to domestic withholding rates.
One important feature of the Russia-India DTT: unlike most Russian tax treaties, it includes a separate article on fees for technical services — covering management fees, consulting fees and technical assistance payments. These are taxed at 10% rather than the domestic 20%, making it advantageous for Indian groups that charge management fees to their Russian subsidiaries.
To apply the reduced 10% withholding rate on dividends paid from a Russian subsidiary to its Indian parent, the Indian company must provide a tax residency certificate before the payment date.
Certificate of residence issued by the Indian Income Tax Department
Apostille under the Hague Convention (India acceded in 2005)
Notarised Russian translation
Must be valid for the calendar year of payment
Submitted to the Russian paying entity before the dividend resolution date
The Russian Federal Tax Service (FTS) has increasingly required beneficial ownership evidence — proof that the Indian parent is the actual beneficial owner of the dividend, not merely a conduit for a third-country beneficial owner. Indian holding companies with substance (employees, office, decision-making) typically satisfy this requirement without difficulty.
If the certificate is not provided in time, the Russian entity must withhold at 15% (domestic rate). The Indian company can then claim a refund from the Russian tax authority, but refund applications take 3–6 months.
Pick what applies — we'll tell you plainly:
Article 13 of the Russia-India DTT contains a provision that most Russian treaties do not: a 10% withholding rate on "fees for technical services" — defined as payments for managerial, technical or consultancy services.
Management fees charged by Indian parent to Russian subsidiary
IT consulting and software development services
Technical assistance in manufacturing or engineering
Professional services (accounting, legal, HR support from India)
Under Russian domestic law, these payments would be subject to 20% withholding. The treaty reduces this to 10% — a significant saving for Indian IT and services companies with Russian clients or subsidiaries.
The same documentation requirements apply: Indian tax residency certificate, apostilled and translated, submitted before payment.
The Russia-India DTT follows the OECD Model on permanent establishment. Key thresholds:
Fixed place of business: A PE is created if an Indian company has a fixed place through which it carries on business in Russia — office, factory, construction site
Construction PE: A building site or installation project constitutes a PE only if it lasts more than 12 months
Service PE: An Indian company that provides services in Russia through its employees for more than 183 days in any 12-month period creates a PE
Agency PE: If a Russian entity acts as a dependent agent of an Indian company — habitually concluding contracts on its behalf — a PE is created regardless of the physical presence
10% with the right documentation — a valid residency certificate and a genuine beneficial owner — against Russia's 15% domestic default. The certificate has to be in place before the payment for the rate to hold.
The treaty has a specific technical-services article, which many treaties don't — it covers management, consulting and technical fees at a defined rate rather than leaving them to full domestic withholding. Using it correctly is what captures the reduced rate on those fees.
Usually format — it must be apostilled, translated, and for the correct year and entity. A certificate that doesn't match the payment period or isn't properly legalised is rejected, so getting the formalities right matters as much as having one.
This sets out the 10% India–Russia rates. The question is applying them, plus one feature many miss: the treaty's separate article on technical-service fees, which can change how your cross-border service income is taxed.
Practical support for international business in Russia.