Double taxation between Russia and Spain

The convention between Russia and Spain has not been terminated. By Decree No. 585 of 8 August 2023, Russia suspended articles 5–22 and 24 — the ones that allocated the right to tax income between the two countries. Article 4 (residence) and article 23 (elimination of double taxation) remain in force: reduced withholding rates in Russia no longer apply, but the tax credit mechanism still works.

The word “suspended” makes it sound as though the treaty no longer exists and tax will have to be paid twice in full. In practice it is more complicated: exactly the part of the convention that allocated taxing rights between the countries has been suspended, while the part on eliminating double taxation remains in force. Let us look at what this means for actual money — dividends, rent, the sale of a flat, a salary from a Russian employer.

Where double taxation comes from

States tax income on two different bases, and they overlap.

• By residence. The country where you are tax resident taxes your worldwide income — wherever it arises.
• By source. The country where the income arises taxes it regardless of where the recipient lives.

You have moved to Spain and become its tax resident, but you still receive dividends from a Russian company — the income is caught in both “nets” at once. Spain wants to tax it as a resident’s worldwide income, Russia as income from a source on its territory. Double taxation treaties exist to resolve this conflict: they determine who taxes first and how much, and the other country must either exempt the income or credit the tax paid abroad. All the options for dividends from your own company — a Russian LLC, a foreign company or a Spanish SL — are covered in Dividends from your own company after moving to Spain.

What a double taxation treaty is

It is an international agreement between two countries. It allocates between them the right to tax different types of income — dividends, interest, salary, property income — and requires the country of residence to credit tax paid in the source country, so that the same income is not taxed twice in full.

Russia and Spain have a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed in Madrid on 16 December 1998. In Spain it was published in BOE No. 161 of 6 July 2000, entered into force on 13 June 2000, and its provisions have applied since 1 January 2001. It replaced the Soviet–Spanish convention of 1985.

What exactly has been suspended since August 2023

Decree of the President of the Russian Federation No. 585 of 08.08.2023 suspended certain provisions of treaties with 38 countries. For Spain the wording is precise: the operation of articles 5–22 and 24 of the convention and of paragraphs II–VIII of the Protocol to it has been suspended.

This is not a “cancellation of the treaty” and not a termination. Termination is governed by article 29 of the convention and requires notice through diplomatic channels at least six months before the end of the calendar year — no such notice was given. The convention formally remains in force; the allocation articles have been “taken out” of it.

Two conclusions that are almost never spelled out.

First: article 4 is in force. If you are formally resident in both countries at the same time, the dispute is not decided on a “first come, first served” basis but by the chain in the convention: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement of the competent authorities.

Second: article 23 is in force. It is this article that obliges Spain to credit tax actually paid in Russia, and Russia to credit tax paid in Spain. This is the key point: the mechanism for eliminating double taxation has formally been kept by both sides.

What about Spain

Spain has not announced any reciprocal measures. The convention with Russia is still listed in the Spanish Ministry of Finance’s official list of treaties in force, and the consolidated text on the BOE website carries no note of suspension — only a note that the convention’s provisions are affected by the 2016 multilateral convention MLI (Spain’s notifications were published in BOE No. 147 of 21.06.2022, Russia’s in BOE No. 108 of 06.05.2023).

In practice this means an asymmetry: Russia has suspended its side of the arrangements, Spain has not. A Russian resident receiving income from Spain can still claim treaty rates. A Spanish resident receiving income from Russia no longer can.

Spain also calculates the credit for its own residents under the treaty. The tax agency’s guide to income from Russia, updated on 8 April 2026, describes it with the treaty limits and no mention of any suspension: Russian tax on dividends is credited up to 15% of their amount, on interest up to 5% (AEAT guide). Russia withholds at its own rates, but Spain credits only what Russia may levy under the treaty. For dividends this changes nothing; for interest, part of the Russian tax is lost.

The situation may change. Before filing a return, check the current status against two primary sources: the Spanish Ministry of Finance’s list of CDIs (double taxation treaties) and the text of Decree No. 585 with subsequent amendments. Links are in the “Sources” section.

Step one: where are you tax resident

All further calculations are meaningless until this status is determined. A detailed breakdown of the criteria is in the article on Spanish tax residence. And it is not determined by a residence permit, by empadronamiento (municipal registration) or by where you “feel” you belong.

Spain — article 9 of Ley 35/2006 (LIRPF)

You are resident if at least one condition is met:

• you spent more than 183 days in Spain in the calendar year (short trips abroad count towards the period of stay unless tax residence in another country is proven);
• the main core or base of your activities or economic interests is in Spain;
• presumption: your spouse, from whom you are not legally separated, and your dependent minor children live permanently in Spain.

Russia — article 207 of the Russian Tax Code

You are resident if you were physically present in Russia for at least 183 calendar days within 12 consecutive months.

Sole proprietor (Russian IP) status, Russian citizenship, registration at a Russian address and open bank accounts do not in themselves create residence.

The year of the move: Spain has no “split year”

In Spain the tax period is the calendar year, and a change of residence does not interrupt it. A person is treated as resident or non-resident for the entire calendar year. If you moved in May and had spent more than 183 days in Spain by 31 December, you are a Spanish resident from 1 January, including January–April when you were still living in Russia.

This is the most common and most expensive mistake of the first year. Income received before the move goes into the Spanish return. It is in exactly this scenario that dual residence most often arises — and this is where article 4 of the convention applies, which Russia did not suspend.

You are resident in Spain and your income comes from Russia

The main scenario for those who moved on a digital nomad residence permit, a startup visa or a non-working residence permit and kept assets in Russia.

Because articles 5–22 are suspended, Russia withholds tax at the domestic rates of the Russian Tax Code, without treaty limits. Spain taxes the same income as the resident’s worldwide income and grants a credit — except for income that only Spain may tax under the treaty, such as salary for work done from Spain.

Sole proprietors on the USN, patent or NPD: why the Russian tax is not credited

The Spanish side looks not at the Russian legal form but at the substance: an individual resident in Spain is carrying on an economic activity. If the work is done from Spain, the treaty gives a clear answer: business profits (article 7) and income from professional services (article 14) are taxed only in the country of residence unless there is a permanent establishment or fixed base in the other country. Spain applies the treaty, and under article 23 it credits only tax that Russia may levy under the treaty. Here that is zero — the same logic as for a salary for remote work.

The second argument is article 80 LIRPF: the credit covers tax “of an identical or similar nature” on income obtained and taxed abroad. The 6% USN and the NPD are levied on revenue, the patent on a potential income set by the region, whereas IRPF is levied on profit. We have not found a DGT ruling on the Russian special regimes specifically, so this argument is secondary; the first one decides. If there is a permanent establishment in Russia — an office through which the business is run — the picture is different and needs a separate review.

Example. A Spanish resident runs a Russian sole proprietorship on the 6% USN with revenue of €120,000 a year; the taxable base in Spain after expenses and social security contributions is €100,000. USN in Russia: €7,200. IRPF in Spain on the general scale (state part plus an average regional part, personal allowance €5,550): €34,847, with no credit. The total is €42,047 a year, about 35% of revenue — €7,200 more than the same income without the Russian tax. What to do with the sole proprietorship itself — keep it, close it or switch to autónomo — is covered in A Russian sole proprietorship while you live in Spain.

Salary from a Russian company while working from Spain: why Russian income tax is not credited

This is the most common trap for people who have moved and keep working remotely for a Russian employer. Russia still withholds personal income tax on this salary after the move (see the row in the table above), but Spain does not credit that tax.

• Under the treaty. Article 15: a resident’s salary is taxed only in the country of residence unless the work is done in the other country. Work done from home in Spain is done in Spain, so only Spain may tax it. Article 23 allows a credit only for tax that Russia may levy under the treaty (treaty text in the BOE). Spain has not suspended the treaty.
• Under Spanish law. The answer is the same without the treaty: Article 80 of the IRPF law credits tax only on income “obtained and taxed abroad” (art. 80 LIRPF), and income from work done in Spain is Spanish-source income (art. 13.1.c of the non-resident income tax law).
• The tax authority’s position. The Directorate General of Taxes (DGT): when you work remotely from home in Spain, the work is treated as done in Spain, whoever benefits from it, and the income is taxed only in Spain (ruling V1162-22). The ruling concerns a British employer, but the rule is general: it comes from the OECD commentary on the employment article.
• If tax was withheld abroad anyway. For an employee of a US company working remotely from Spain, the DGT says it directly: the deduction for international double taxation does not apply, and the tax withheld can be reclaimed in the country that withheld it (ruling V1265-22). The same conclusion for a British employer with no office or clients in Spain is in ruling V2883-23.
• What can be credited. Only tax on salary for days when you physically worked in Russia: Russia may tax that income under Article 15.

Can the tax be reclaimed in Russia

For 2024 and later — as a rule, no. Since 1 January 2024, pay for remote work under an employment contract with a Russian company is Russian-source income wherever the employee is (art. 208(1)(6.2) of the Russian Tax Code, introduced by Federal Law No. 389-FZ of 31.07.2023), and a non-resident pays NDFL on it on the 13–22% scale (art. 224(3.1)). Under Russian law the tax has been withheld correctly, and article 15 of the treaty, under which Russia would have had to give it up, is suspended by Russia. For 2023 and earlier it was different: a non-resident’s salary for work done abroad was foreign-source income, and NDFL withheld in excess was refunded by the employer (art. 231 of the Russian Tax Code) within three years of payment.

The result is real double taxation: Russian income tax and full Spanish IRPF on the same salary. There are ways out, but each changes both your Russian and your Spanish obligations: a different arrangement with the company, reclaiming the tax in Russia for years before 2024, the Beckham regime for employees. It is best settled before your first Spanish return — in a review of your situation.

How the credit is calculated in the Spanish return

The mechanism is set out in article 80 of Ley 35/2006 (deducción por doble imposición internacional). The tax liability is reduced by the lower of two amounts:

1. the amount actually paid abroad in a tax of an identical or similar nature;
2. the result of applying the average effective rate of Spanish tax (tipo medio efectivo de gravamen) to the part of the tax base that was taxed abroad.

The second point is exactly where “residual” double taxation comes from. If more was withheld abroad than Spain would have charged on its own base, the difference is not refunded and cannot be credited anywhere. A TEAC ruling of 20 October 2025 further clarified that the part of the base taxed abroad is calculated under Spanish rules, not on the amount on which the foreign tax was paid.

Example 1. Dividends: no double taxation arises

Dividends from a Russian company: €10,000. There is no other income in the savings base.

• Russia withholds 15% → €1,500
• Spain, savings base: 6,000 × 19% = €1,140; 4,000 × 21% = €840 → €1,980
• Average effective savings rate: 1,980 / 10,000 = 19.80%
• Credit: the lower of €1,500 and €1,980 → €1,500
• Payable in Spain: 1,980 − 1,500 = €480

The total burden is €1,980, i.e. exactly the Spanish rate. There is no double taxation.

Example 2. Selling a flat: double taxation really does arise

A flat in Russia was bought for €120,000 and sold for €200,000 before the minimum ownership period expired.

• Russia: 30% of the full proceeds, with no deduction of costs → €60,000
• Spain: gain of €80,000. 6,000 × 19% = €1,140; 44,000 × 21% = €9,240; 30,000 × 23% = €6,900 → €17,280
• Average effective rate: 17,280 / 80,000 = 21.60%
• Credit: the lower of €60,000 and €17,280 → €17,280
• Payable in Spain: €0

€42,720 of Russian tax is not credited anywhere. The total burden is €60,000 instead of €17,280.

And here is the most useful observation from this case: if the minimum ownership period is met, Russian NDFL is zero, and in Spain you pay the same €17,280. The ownership period matters more than the state of the treaty. Selling Russian property is the kind of transaction whose date is worth planning in advance, rather than looking afterwards for somewhere to set off the tax you have paid.

Example 3. The Beckham Law changes the whole picture

The special regime for inbound workers (article 93 LIRPF, commonly known as the “Beckham Law”) lets you pay tax as a non-resident in the year of the move and the following five years: at a flat rate of 24% on Spanish-source income up to €600,000 a year and 47% above that. Employment income is taxed worldwide, but foreign dividends, interest, rent and capital gains are not taxed in Spain at all. On top of that, there is an exemption from Modelo 720 and wealth tax applies only to assets in Spain.

For example 1 this means 15% in Russia and zero in Spain. The question of double taxation on this income simply disappears.

Caveats that usually get lost: the regime is available only to those who were not Spanish tax residents in the five tax periods before the move; it is claimed on Modelo 149 within six months of registering with the social security system or starting the activity; the annual return is filed on Modelo 151; personal and family allowances do not apply. Missing the Modelo 149 deadline closes off the regime, even if all other conditions are met.

Which Russian taxes are credited in Spain

A summary by type of income for a Spanish tax resident who is not under the Beckham Law. The article 80 LIRPF cap always applies: Spain deducts no more than its own tax on the same part of the base.

How to report income from Russia in the Renta return

The draft return knows nothing about Russian income: it is entered by hand in Modelo 100. Box numbers are those of the 2025 form (Orden HAC/277/2026).

• Dividends from a Russian LLC or shares — box 0029, gross of withholding. The Russian tax goes into the deduction for international double taxation, box 0588, up to 15% of the dividends.
• Interest on deposits — box 0027. The deduction goes into the same box 0588, up to 5% of the interest.
• Renting out a flat — the section on let property: income, expenses, depreciation. The net income is reduced under article 23.2 LIRPF (box 0150), and the reduction applies to a home abroad if it is let as the tenant’s permanent home (ruling V0617-22). The size depends on the date of the lease: signed before 26 May 2023 — 60%; between 26 May 2023 and 1 December 2026 — as a rule 50%, because the higher 60–90% rates require refurbishment, social letting or a Spanish stressed-market zone. For leases after 1 December 2026, Real Decreto-ley 29/2026 introduces a new scale; as of 19 October 2026 Congress has not approved it.
• Exchange rate. Amounts are converted into euros at the official rate — the one published by the European Central Bank or the Bank of Spain (ruling V0128-20). The ECB has not published a rouble rate since 2 March 2022, and we have not found AEAT guidance on a substitute. Choose a method — for example, the rate at which you actually converted — keep the evidence and apply it to all the year’s income in the same way.

A rental example. A flat in Moscow worth about €300,000 is let for €18,000 a year under a 2024 lease. Russia takes 30% of a non-resident’s income with no deduction of costs — €5,400. In Spain €12,000 remains after expenses and depreciation; minus 50%, €6,000 goes into the base. If the person’s whole general base is €60,000, their average rate is 28.08%, and the Spanish tax on this rent is €1,684.80. The credit is the lower amount, €1,684.80: nothing more is payable in Spain, and €3,715.20 of Russian tax is not credited anywhere. With Russia’s 30%, the Spanish reduction saves no money: it lowers both the Spanish tax and the credit cap.

Certificate of residence: necessary but not sufficient

Article 4 of the convention has not been suspended, and it is what resolves conflicts of dual residence. But you cannot apply it mechanically by producing a piece of paper — the case law of the Spanish Supreme Court in recent years has settled into a clear line.

Conclusion: the certificate opens the analysis rather than concluding it. A certificate from the Russian Federal Tax Service is essential, but you will not win a dispute with it alone.

What this looks like in a real case

A judgment of the Catalan High Court of 6 October 2025. A person with dual Spanish and Andorran citizenship moved to the Principality at the end of 2017 and argued that in 2018 he was not a Spanish tax resident. He had an Andorran certificate of residence, a home rented from August 2017 and one bought from June 2018.

Since he had a permanent home in both states, the second criterion applied — the centre of vital interests. The combination of factors worked against the taxpayer: a Spanish pension of over €34,000, the surrender of pension plans with Spanish entities worth about €120,000, four properties in Spain, his wife, daughters and grandson living in Spain, and his wife filing an IRPF return.

The key logic: the court did not deny his ties with Andorra — it found them relatively less close. What wins is not the absence of ties with another country but the objectively greater closeness of ties with Spain when all circumstances are weighed.

And the most unpleasant part: the court upheld a penalty for a serious infringement, finding negligence. A difference in interpreting the convention’s criteria does not in itself exempt you from liability if the objective facts speak clearly enough.

How status is proven

The file is built up over the course of the year, not when a request arrives. What the tax authority checks and how it is covered:

• days of presence — boarding passes, a documented travel diary, statements showing spending abroad;
• short trips abroad — a chronological log of movements, accommodation contracts abroad;
• core of interests, income — contracts with foreign clients, invoices, a foreign tax return;
• core of interests, assets — bank statements, investment portfolios, property documents;
• core of interests, management — corporate minutes, an office or coworking contract, IP addresses used to access work systems;
• permanent home — a lease or title deed, utilities in your name;
• family presumption — your spouse’s certificate of residence, documents on the children’s schooling.

A separate item is your digital footprint. Online banking, electronic signatures, video meetings and activity on platforms let the authorities reconstruct where the activity is actually carried out from. Conflicts arise exactly where the footprint does not match what was declared. Zero electricity consumption in a flat declared as the main home is one of the most common arguments against a claimed status.

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You are resident in Russia and your income comes from Spain

Here the other half of the asymmetry applies: Spain applies the convention, so treaty rates are available.

To apply the treaty rate, the Spanish payer or bank needs your Russian tax residence certificate issued by the Russian Federal Tax Service and drawn up “for the purposes of the convention”. Without it, tax is withheld at the domestic rate and a refund has to be claimed separately.

Two limitations worth knowing in advance. Paragraph V of the Protocol to the convention denies treaty benefits on dividends, interest, royalties and capital gains to a company more than 50% owned by non-residents of its own country if it does not carry on substantial business activity. The convention is also covered by the MLI, which means the principal purpose test applies: a benefit is not granted if obtaining it was one of the main purposes of the structure.

A separate issue is the deduction of rental expenses for non-residents outside the EU. In July 2025 the Audiencia Nacional (National High Court) found the difference in treatment to be contrary to EU law, but the state has appealed the decision to the Supreme Court, and the Spanish tax agency continues to apply the previous approach: 24% of gross income. The outcome is worth watching, but it is too early to base calculations on it.

The reverse credit in Russia

Article 232(1) of the Russian Tax Code allows tax paid abroad to be credited only if this is provided for by an international treaty. Article 23 of the convention, which provides exactly that, is not among the suspended articles. The formal basis for the credit therefore remains. Given that practice on this issue since 2023 is still taking shape, it is worth confirming your position on a specific type of income in advance, not when filing the 3-NDFL return.

What to file and when

Certificates of residence are needed in both directions. The Spanish certificado de residencia fiscal is requested from the AEAT electronic office — note that there are two different versions, and to apply the convention you need the one issued “a efectos de Convenio”. The Russian certificate confirming tax resident status is requested through the Russian Federal Tax Service online service. How to get it, which year it is issued for and what to do about the apostille is covered separately: confirming tax resident status.

Modelo 720 is an information return; no tax is paid on it. But failing to file it is penalised with a fine regardless of whether tax was underpaid. A 2022 judgment of the EU Court of Justice struck down the previous disproportionate penalties, but the obligation itself remains in full. A Russian flat and an account in a Russian bank are included in it.

Seven costly mistakes

1. “The treaty was cancelled, so it no longer exists.” The allocation articles have been suspended. Residence under article 4 and the credit under article 23 still work.
2. “There is no treaty, so there is no need to declare in Spain.” The obligation to declare worldwide income stems from Spanish law, not from the convention. Exchange of information under article 26 was not suspended.
3. Expecting a split year when you move. Spain does not have one. Income from January–April goes into the return even if the move was in May.
4. Calculating the credit from the Russian tax base. The limit is calculated from the Spanish base under Spanish rules — this was expressly confirmed by the TEAC ruling of 20.10.2025.
5. Selling Russian property without checking the ownership period. The difference between “before” and “after” the minimum period in the example above is €42,720.
6. Missing the six-month Modelo 149 deadline. The Beckham Law is lost for all six years, even if every other condition is met.
7. Assuming a Russian sole proprietorship “will stay in Russia”. Spain assesses the substance of a resident’s activity, and tax under the USN, a patent or the NPD for work done from Spain is, as a rule, not credited. What to do with the sole proprietorship itself — keep it, close it or switch to autónomo — is covered separately: a Russian sole proprietorship when you live in Spain.

If dividends from a foreign company go to a Spanish company rather than to you personally, a different regime applies — see our article on a holding company in Spain.

Frequently asked questions

Is the double taxation treaty between Russia and Spain in force in 2026?

Yes, the convention of 16.12.1998 has not been terminated. By Decree No. 585 of 08.08.2023, Russia suspended articles 5–22 and 24 and paragraphs II–VIII of the Protocol. Articles 1–4, 23, 25, 26 and 27 remain in force.

Has Spain suspended the convention on its side?

No such announcement has been made. The convention is listed among the treaties in force by the Spanish Ministry of Finance, and the consolidated BOE text carries no note of suspension. The status is worth re-checking before filing a return.

Can Russian tax be credited in the Spanish return?

Yes. The mechanism is article 80 LIRPF: the lower of two amounts is deducted — the tax actually paid abroad or the average effective Spanish rate applied to the part of the base taxed abroad. You need documents proving the withholding. For dividends the credit is capped at 15% of their amount, for interest at 5%.

Is tax under the USN, a patent or the NPD credited in Spain?

As a rule, no. If the work is done from Spain and there is no permanent establishment in Russia, under articles 7 and 14 of the treaty only Spain taxes this income, and the article 23 credit is available only for tax that Russia may levy under the treaty. With revenue of €120,000 and a Spanish base of €100,000, that is €7,200 of USN plus €34,847 of IRPF — €42,047 a year.

Can I reclaim Russian income tax on a salary from a Russian company if I work from Spain?

For 2024 and later — as a rule, no: since 2024, pay for remote work under an employment contract with a Russian company is Russian-source income wherever the employee lives (art. 208(1)(6.2) of the Russian Tax Code). Spain does not credit this tax either. For 2023 and earlier, tax withheld in excess was refunded by the employer within three years of payment.

Is Spanish tax on renting out a flat in Russia reduced?

Yes. The reduction of net income under article 23.2 LIRPF also applies to a home abroad if it is let as the tenant’s permanent home (DGT ruling V0617-22). For leases signed before 26 May 2023 it is 60%; for leases between 26 May 2023 and 1 December 2026, as a rule 50%.

Which exchange rate should be used to convert roubles into euros for the Spanish return?

The official rate of the ECB or the Bank of Spain (DGT ruling V0128-20). But the ECB has not published a rouble rate since 2 March 2022, and the tax agency has not said what to use instead. Choose a method, for example the rate at which you actually converted, keep the evidence and apply it consistently.

How much will be withheld in Russia on dividends if I live in Spain?

15% NDFL at the domestic rate for non-residents. The 5% and 10% treaty rates under article 10 of the convention are currently unavailable because that article is suspended.

I sold a flat in Russia — will I pay tax twice?

Possibly, in part. Russian tax for a non-resident is 30% of the full proceeds with no deduction of costs, while the Spanish credit is limited to the Spanish tax on the same gain. The difference is not recovered. If the minimum ownership period (3 or 5 years) is met, no Russian tax arises at all — since 2019 the exemption has also applied to non-residents.

Does the Beckham Law help?

For foreign dividends, interest, rent and capital gains — yes: while the regime applies they are not taxed in Spain. For employment income — no, it is taxed worldwide, but at a flat rate of 24% up to €600,000.

Do I need to file Modelo 720 if I still have accounts and a flat in Russia?

Yes, if the value in any of the three blocks — accounts, securities and insurance, property — exceeds €50,000. The blocks are counted separately. Deadline: 1 January to 31 March. Those under the Beckham Law are exempt from this obligation.

Which CIS countries have a double taxation treaty with Spain?

Kazakhstan (in force since 18.08.2011), Armenia, Azerbaijan, Belarus, Georgia, Moldova and Uzbekistan have their own treaties. For Tajikistan and Ukraine the 1985 treaty with the USSR still applies. There is no treaty with Kyrgyzstan or Turkmenistan. Source: the Spanish Ministry of Finance list.

What should I do in the year of the move if I am formally resident in both countries?

Apply article 4 of the convention — it has not been suspended. The sequence of criteria: permanent home, centre of vital interests, habitual abode, nationality, mutual agreement of the competent authorities. Gather evidence in advance: a lease or title deed, utility bills, bank statements, documents on the children’s schooling.

I am resident in Russia and let a flat in Spain — what is the rate?

24% of gross income with no deduction of costs, with a quarterly Modelo 210 return. The reduced 19% rate and the right to deduct expenses are available to EU and EEA residents. Case law on this difference is currently changing, but the tax agency applies the previous approach.

Sources

• Convention between the Government of the Russian Federation and the Government of the Kingdom of Spain for the avoidance of double taxation of 16.12.1998 — BOE-A-2000-12779
• Decree of the President of the Russian Federation No. 585 of 08.08.2023 — kremlin.ru
• The Spanish Ministry of Finance’s list of CDIs in force — hacienda.gob.es
• Ley 35/2006 (LIRPF), arts. 9 and 80; Ley 19/1991 (Impuesto sobre el Patrimonio, wealth tax), art. 32
• Agencia Tributaria: guide to income from Russia for Spanish residents — sede.agenciatributaria.gob.es
• Russian Tax Code: arts. 207, 208, 210, 217, 224, 231, 232; Federal Law No. 389-FZ of 31.07.2023
• DGT rulings: V1162-22, V1265-22, V2883-23 (salary for remote work), V0617-22 (reduction for letting a home abroad), V0128-20 (exchange rate)
• Ley 35/2006, art. 23.2 and transitional provision 38 as amended by Real Decreto-ley 29/2026; the 2025 Modelo 100 form — Orden HAC/277/2026
• European Central Bank on discontinuing the rouble rate, 02.03.2022 — ecb.europa.eu
• TEAC ruling of 20.10.2025 on calculating the deduction under article 80 LIRPF

This article is for information only and reflects the law as of the date of publication. Tax consequences depend on specific circumstances: the composition of income, dates, documents and the structure of assets. Before making decisions, check the current wording of the rules against the primary sources.

Key points

• The convention between Russia and Spain of 16 December 1998 has not been terminated by either side.
• By Presidential Decree No. 585 of 8 August 2023, Russia suspended articles 5–22 and 24 of the convention and paragraphs II–VIII of its Protocol.
• Not suspended are articles 1–4 (including the rules for determining residence), article 23 (elimination of double taxation), and articles 25, 26 and 27.
• Spain has not declared any suspension: the convention is listed among the CDIs in force by the Spanish Ministry of Finance, and the consolidated BOE text carries no note of suspension.
• The practical result: reduced withholding rates in Russia no longer apply, but the tax credit mechanism works — both in the Spanish return and, formally, in the Russian one.

Need your situation reviewed?

If you still have assets in Russia and your tax residence is changing or has already changed, the course of action is determined before the end of the calendar year, not when you file your return. An express case check takes 10 minutes, by message, no calls. Review your situation