Türkiye–Russia double taxation agreement

This page is for Turkish citizens who work in Russia, earn income from Russia, or live in Russia and receive income from Türkiye. The agreement between Türkiye and Russia prevents the same income from being taxed in both countries. Below, you will find who the agreement applies to, in which country income such as salary, pension, dividends and interest is taxed, how the tax paid is credited, and where to obtain the required certificate of residence. For income tax rates in Russia, see R9.1.

• Full name: "Agreement between the Government of the Republic of Türkiye and the Government of the Russian Federation for the Avoidance of Double Taxation with Respect to Taxes on Income".
• Dates:
  • Signature: 15 December 1997
  • Official Gazette: 17 December 1999, issue 23909
  • Entry into force: 31 December 1999
  • Application: since 1 January 2000
• Taxes covered (Art. 2):
  • In Russia: taxes on corporate profits and personal income tax (налог на доходы физических лиц, НДФЛ)
  • In Türkiye: personal income tax and corporate tax
• In 2023, Russia suspended many provisions of its tax agreements with certain countries (Federal Law 598-FZ, 19 December 2023). The agreement with Türkiye is not on the list in this law. The Russia agreement is also included in the Revenue Administration's list of agreements in force.
• The Turkish text of the agreement is published on the website of the Revenue Administration (GİB), and the Russian text on the website of the Federal Tax Service of Russia (ФНС России).

• The agreement applies to persons who are residents of one or both countries (Art. 1). Residence, not citizenship, is decisive.
• A resident is a person who is liable to tax in that country under its legislation because of a home, residence or similar criterion (Art. 4/1).
• In Russia: a person who is physically present in Russia for at least 183 calendar days during any consecutive 12-month period is a Russian tax resident (Tax Code Art. 207/2). For details, see R9.1.
• If you are considered a resident of both countries, the agreement decides in the following order (Art. 4/2):
  • First: the country where you have a permanent home available to you
  • If you have a home in both countries: the country with which your personal and economic relations are closer (centre of vital interests)
  • If this cannot be determined: the country where you have a habitual abode
  • If that cannot be determined: the country of which you are a national
  • If you are a national of both countries: the competent authorities of the two countries decide by mutual agreement

• General rule (Art. 15/1): If you work in Russia as a resident of Türkiye, the remuneration for work performed in Russia may be taxed in Russia.
• Cases taxed only by Türkiye (Art. 15/2). All three conditions must be met:
  • you do not spend more than 183 days in Russia during that calendar year
  • the remuneration is paid by, or on behalf of, an employer who is not a resident of Russia
  • the remuneration is not borne by a permanent establishment or fixed base that the employer has in Russia
• Construction sites and international transport (Art. 15/3). Remuneration paid for the following work is not taxed in the other country where the work is performed:
  • work connected with a construction site, construction, assembly or installation project referred to in Art. 5(3)(a) of the agreement
  • work performed aboard a ship, aircraft or road vehicle operated in international traffic by an enterprise of a Contracting State
• When does a construction site become a permanent establishment (Art. 5/3): A construction site, construction, assembly or installation project lasting more than 18 months constitutes a permanent establishment. The period is counted from the day the contractor begins work, including preparatory work, until the date of provisional acceptance. This rule directly concerns Turkish contractors working in Russia.
• Other special cases: Journalists receiving payments from sources in Türkiye are exempt from tax in Russia for 2 years (Art. 15/4). Directors' fees are taxed in the country of the company (Art. 16), while artists' and athletes' income may be taxed in the country where the activity is performed (Art. 17).

• Pensions (Art. 19): Pensions paid in consideration of past employment may be taxed only in the country of which you are a resident.
• Public-service salaries and pensions (Art. 18): Salaries and pensions paid by the state or a local authority for public service are generally taxed only in that state. If the person is both a resident and a national of the other country, they are taxed only in that other country.
• Students and trainees (Art. 20/1): Payments received from outside the country where you are present solely for study or vocational training, for your maintenance and education, are not taxed there.
• Teachers and researchers (Art. 20/2): Income earned by a person present primarily for teaching or research is exempt from tax for 2 years if the payment is made from outside that country.

• Dividends, interest and royalties (Arts. 10–12): The country where the income arises may also tax it. If the recipient is the beneficial owner, this tax may not exceed 10% of the gross amount.
• For comparison, Russia's domestic rates (Tax Code Art. 224/3, text dated 4 August 2026): Income of non-residents of Russia is generally taxed at 30%. The rate is 15% for dividends received from Russian companies and interest on deposits in Russian banks. For residents of Türkiye, the agreement limits source-country tax on dividends, interest and royalties to 10%.
• Immovable property (Arts. 6 and 13/1): Rental income and capital gains may be taxed in the country where the immovable property is located.
• Gains from the sale of shares and bonds (Art. 13/4): They are taxed only in the country where the seller is resident. However, if the period between acquisition and sale does not exceed 1 year, the country where the gain arises may also tax it.
• Other income not mentioned in the agreement (Art. 21): It is taxed only in the country where you are resident.

• Rule of the agreement (Art. 22): Tax paid in the other country is credited against the tax payable on the same income in your country of residence. The credit may not exceed the tax calculated in your country of residence for that income.
• If you are a resident of Russia and paid tax in Türkiye (Tax Code Art. 232):
  • The credit is claimed with an annual tax return. A certificate of income and tax issued or certified by the Turkish competent authority, together with a notarized Russian translation, must be attached.
  • The credit may be claimed within 3 years following the year in which the income was earned.
• If you are a resident of Türkiye and receive income from Russia (Art. 232/6–9):
  • The Russian entity making the payment (the withholding party, налоговый агент) applies the exemption or reduced rate under the agreement. If your passport is insufficient to demonstrate residence, it will request an official certificate of residence and its notarized Russian translation.
  • If you provide the certificate after payment, the tax withheld is refunded. If the paying entity no longer exists, you apply to the Russian tax office for a refund.
• Credit in Türkiye: Keep your Russian tax documents. Consult your tax office or the GİB Tax Communication Centre regarding filing and credit procedures.

• From Türkiye (for use in Russia). Under GİB's Circular on Double Taxation Agreements/3 dated 20 December 2013, Turkish citizens who are full taxpayers in Türkiye obtain the certificate from the following authorities:
  • Ankara, Antalya, Bursa, Istanbul, Izmir, Kocaeli and Trabzon Tax Office Directorates: persons with continuous tax liability at affiliated tax offices and Turkish citizens residing in their regions without continuous tax liability
  • Large Taxpayers Tax Office Directorate: its own taxpayers
  • Revenue Administration (Department of European Union and Foreign Affairs): other persons
• The sample petition in the annex to the Circular (ANNEX-1) is submitted with the application. If it is requested for a past year, a document showing that you resided in Türkiye that year (the "Address Information Report" from the civil registry office) is attached.
• From Russia (for use in Türkiye). Apply by email or through your Gosuslugi account via the Federal Tax Service's online service "Confirmation of Russian tax residence status" (Подтверждение статуса налогового резидента). The status and result of the application are displayed in the same service. The recipient institution can verify the certificate in the same service using the verification code.
• In Türkiye, submit the Russian certificate to the tax office or tax officer together with the original and a Turkish translation certified by a notary or the Turkish consulate. If the certificate is not provided, Turkish domestic law applies.

• If the actions of one or both countries result in taxation contrary to the agreement, you may bring the matter to the competent authority of the country where you are resident, independently of remedies under domestic law (Art. 24/1).
• Application period:
  • general rule: 3 years from the first notification of the taxation contrary to the agreement
  • for Türkiye: 1 year from the first notification. After this period has elapsed, an application may still be made to the Turkish competent authority within 5 years from 1 January of the year following the relevant tax period.
• If the competent authority (the Ministries of Finance of the two countries under the agreement) considers the objection justified but cannot resolve it itself, it tries to reach a mutual agreement with the competent authority of the other country (Arts. 3 and 24/2).
• Non-discrimination (Art. 23): Nationals of one country may not be taxed in the other country more heavily than nationals of that other country in the same circumstances.

• GİB Tax Communication Centre (VİMER) — your tax procedures and questions in Türkiye
  • Telephone: 189 (within Türkiye), +90 312 189 11 22 (from abroad)
  • Hours: weekdays 09:00–18:00
• Embassy of the Republic of Türkiye in Moscow, Treasury and Finance Counsellor's Office
  • Address: 7 Rostovskiy Pereulok No: 12, 115127 Moscow
  • Telephone: +7 495 994 48 08 (extension 1177)
• Federal Tax Service of Russia (ФНС России) — residence certificates, withholding and refund procedures
  • Information line: +7 800 222-22-22 (within Russia)
  • Address of your tax office: "Address and payment details of your tax office" service
  • Appointment: order.nalog.ru
  • Written question: "Application to the FNS" service

• Thinking, "I am a Turkish citizen, so the agreement automatically protects me." Residence is decisive under the agreement.
• Assuming that your salary will be taxed only in Türkiye even though you spend more than 183 days in Russia in a calendar year.
• Failing to provide the certificate of residence to the Russian employer or bank before payment. In that case, tax is first withheld at Russia's domestic rate and you must then seek a refund.
• Submitting the certificate without a translation.
• Missing the 3-year period for claiming a credit in Russia for tax paid in Türkiye.
• Overlooking Türkiye's 1-year application period under the mutual agreement procedure.

• Is the agreement still in force? Yes. It is included in GİB's list of agreements in force. Türkiye is not included in the list of agreements whose provisions Russia suspended in 2023 (598-FZ).
• My Turkish company is sending me to Russia for a few weeks. Will I pay tax in Russia? If you do not spend more than 183 days in Russia during the calendar year, your remuneration is paid by your Turkish employer, who is not a resident of Russia, and the remuneration is not paid from the employer's permanent establishment in Russia, it is taxed only in Türkiye (Art. 15/2).
• I live in Russia. Where is my pension from Türkiye taxed? Pensions paid for past employment may generally be taxed only in the country where you are resident (Art. 19). Article 18/2 applies to pensions arising from public service. Ask your tax office which category your pension belongs to.
• How much tax will be withheld from interest on my deposit in a Russian bank? If you are a resident of Türkiye and document your residence, the agreement limits source-country tax to 10% (Art. 11). If you are a resident of Russia, Russia's domestic rates apply (see R9.1).
• I am studying in Russia. Is the money my family sends from Türkiye taxed? Payments received from abroad for the maintenance and education of a student present solely for study are not taxed in the country of study (Art. 20/1).

• GİB – Turkish text of the Türkiye–Russia agreement (PDF)
• Federal Tax Service of Russia – Russian text of the agreement (DOC)
• GİB – List of double taxation agreements in force (PDF)
• GİB – Circular on Double Taxation Agreements/3: certificate of residence
• GİB – Sample petition for a certificate of residence, for Turkish citizens (ANNEX-1, DOC)
• Federal Tax Service of Russia – Tax residence confirmation service
• Federal Tax Service of Russia – Personal account (личный кабинет)
• Federal Tax Service of Russia – Tax office address search