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Navigating new territory Internationally Mobile Employees International Assignment Services Taxation of International Assignees Country – Russia

Human Resources Services

International Assignment Taxation Folio

Country: Russia

Introduction: International assignees working in Russia 4

Step 1: Understanding basic principles 5

Step 2: Understanding the Russian system 6

Step 3: What to do before you arrive in the Russian Federation 10

Step 4: What to do when you arrive in the Russian Federation 12

Step 5: What to do when you leave the Russian Federation 13

Step 6: Other matters requiring consideration 14

Appendix A: Double-taxation agreements 15

Appendix B: Social security reciprocal agreements 17

Appendix C: Russia contacts and offices 18

Additional Country Folios can be located at the following website: www.pwc.com/ias/folios

International Assignment Taxation Folio 3

Introduction: International assignees working in Russia

Russian tax legislation continues to This folio is not intended to be be subject to frequent change as well comprehensive. Advice based on as different interpretations that may specific circumstances and reflecting be taken by the authorities. This any subsequent developments in law folio is based on law and practice as and practice should be sought before of 1 August 2013 and is designed to any specific decisions are made. The assist both the foreign employee and team of professionals at employer in dealing with PricewaterhouseCoopers is able to and social security issues related to advise on structuring compensation the Russian Federation. packages and to assist with all necessary formalities for both expatriates and their employers. Using the PricewaterhouseCoopers international network, advice can be provided on all aspects of international employment and reward..

Last updated: July 2013 This document was not intended or written to be used, and it cannot be used, for the purpose of Menu avoiding tax penalties that may be imposed on the taxpayer.

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Step 1: Understanding basic principles

The scope of taxation year by counting the days spent Russian tax authorities in Russia in Russia within the relevant generally accept passport calendar year. In this regard the stamps to prove the number of 1. An international assignee approach remains the same as days spent in Russia. No other transferred by his/her employer under the previous legislation: factors impact tax residence to the Russian Federation will, in order to enjoy the 13% status under the current law. in general, become liable to resident , the taxpayer Russian tax. The extent to which should spend at least 183 days Husband and wife an international assignee will be in Russia in a calendar year. 5. Where both husband and wife affected by Russian taxation will have income that may be subject depend on the number of days A Russian resident taxpayer, i.e. to tax in the Russian Federation, the assignee is in Russia in a an individual who spends at each is obligated to pay Russian calendar year and the nature of least 183 days in a calendar year income tax on a separate basis. activities the assignee performs in Russia, is liable to personal There is no concept of joint tax in Russia. In addition, the income tax on his/her returns in Russia. domestic legislation which worldwide income at a flat rate governs the taxation of the of 13% on most types of income. international assignee may, in The income tax payable is some instances, be modified by calculated on annual taxable the provisions of any applicable income after the deduction of double . personal allowances. However, these allowances are phased out The tax year entirely at relatively low levels of income. As a result, they are of 2. The Russian tax year runs from no value to most expatriates. 1 January to 31 December. 4. A non-resident taxpayer, i.e. an Methods of individual who spends under calculating tax and 183 days in Russia in a calendar tax residence year, is subject to Russian income tax at 30% only on 3. According to the rules stipulated his/her Russian source income, in Chapter 23 (Personal Income which generally includes all Tax) of the Russian Tax Code an employment income received in individual is considered to be a connection with his/her Russian tax resident if he/she activities in Russia as well as spends in Russia not less than various types of investment 183 days during 12 consecutive income received in Russia. months. However, the Ministry Special beneficial tax rate of 13% of Finance of the Russian is applied to income of non- Federation has issued several residents received by them letters clarifying some under Highly Qualified ambiguities in applying the tax Specialist (HQS) work permit. residence rules. The letters imply that the "final" tax status of an individual taxpayer shall be defined for a whole calendar

International Assignment Taxation Folio 5

Step 2: Understanding the Russian tax system

Taxation of • Bonuses, cost of living Income tax rates individuals allowances, and similar payments which are received 12. Currently, the following rates of Taxable income in respect of living in Russia; personal income tax apply: 6. Taxable income for Russian • • Food and travelling expenses For tax residents: resident individuals is defined of the taxpayer's family and as total income received in the • 13% for most types of income, housing costs, irrespective of year from all sources. incl. employment income; whether they are paid directly 7. Where income is received in by the employer or • 9% on dividends from both foreign currency, it is converted reimbursed to the expatriate. Russian and non-Russian to roubles at the exchange rate sources; and on the date the income is Other allowances • 35% on cost of winnings and received by the individual or, for and exemptions prizes received during salary payments, on the last day 10. In addition to the tax allowances competitions, games and of the month for which income mentioned above, there are other events held for is received. benefits that may be granted to advertising purposes (in the employees by their employer 8. Certain types of income are, part exceeding RUB 4,000) however, specifically excluded which are exempt from tax. For and an interest on deposits from taxable income, the most example: with Russian banks where the interest so charged is above significant of which are • Sums paid by the employer prescribed norms and a listed below: from net profit for the medical material benefit received in treatment of employees and • Certain social security and form of interest paid on any their families at licensed pension benefits; forms of loan where the medical organizations, subject interest so charged is below • Certain redundancy to submission of supporting prescribed norms (5.5% and payments; documentation; 9% at 1 August 2013 for RUB • Expenses in carrying out • School fees if paid directly by and foreign currency loans employment duties, subject to employer to educational respectively). modest limits; institutions; • For tax non-residents: • Interest on bank deposits in • Sums paid to employees in • 15% on dividends received Russian banks (within limits); excess of salary in certain from Russian companies; circumstances up to RUB • Proceeds from the sale of 4,000. • 30% on all other types of private property, up to certain income; limits (see also details below). 11. Goods and services given by the employer to the employee (or by • 13% on remuneration of HQS 9. Where the Russian resident an organization to an individual and foreign nationals, taxpayer is an international in general) are included in employed by individuals for assignee, the following amounts taxable income based on their certain purposes. are included in taxable income value at the date received. (there is no expatriate tax regime):

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Double taxation Capital gains purchase and the respective tax agreements may be deducted from the 17. Taxable capital gains from the taxable income at sale. 13. The determination of residence sale of assets (excluding status is often modified by the securities) may be calculated in 20. Deductions under both the provisions of double tax treaties. one of two ways at the option of direct and notional methods for Most treaties use various tests to the taxpayer - under the direct the sale of property (excluding determine in which of two method or notional method. securities) are available only to countries an individual is Under the direct method the tax residents. resident for treaty purposes. taxable gain is the difference Usually the following factors are between the sales price and the Purchase of property original cost of the asset. In considered when determining a 21. Expenditures incurred by an order to use the direct method a place of residence: individual on the acquisition or taxpayer must have construction of an apartment or • Permanent home; documentary evidence verifying house and respective land plot the original cost of the asset. • Personal and economic and payment of interest on bank The gain is calculated in relations; loans obtained for these Roubles, even if the sale or purposes are allowed as a purchase is made in a foreign • Nationality. deduction of up to RUB currency. Under the notional 2,000,000 plus the amount of 14. Many method, gross sale proceeds less interest paid to the bank agreements exempt certain a certain amount is subject to (without a limitation). This is a types of foreign source income income tax. Particularly, the once-in-a-lifetime deduction from tax. For employment following rules apply to the sale and it is available to tax income an exemption could be of property under the notional residents only. granted for a resident of another method: state and non-resident of Russia Social deductions if the income is generated from • Proceeds from the sale of real a company without a permanent property and land held for 22. Social deductions are available establishment in Russia. under three years are tax for tax residents in respect of exempt up to the limit of RUB funds expended during the tax 15. For other income received by 1,000,000 p.a.; year on medical treatment treaty residents of Russia from (including purchase of • foreign sources Russia applies a Proceeds from the sale of medicines), education, charity foreign , but only if other property (excluding and contributions to Russian income is received from a securities) held for less than non-state Pension plans. Such country which has a double three years are tax exempt deductions may be claimed by taxation agreement with Russia. up to the limit of RUB filing necessary supporting Receiving a in 250,000 p.a. documentation with the tax practice is extremely difficult 18. However, property (excluding return. Social deductions due to strict documentary securities) held for three years (without deduction on children’s requirements. or more is not subject to tax education) may generally be claimed up to the limit of RUB 16. The full list of countries with when sold under either method 120,000 per annum. Social which Russia currently has of computing tax on capital gains. deductions are available only to double-taxation treaties, and tax residents. recognized by Russia, may be 19. Capital gain for transactions found in Appendix A. A number with securities may be Net wealth of additional treaties are calculated only under direct presently under negotiation or method. However, expenses ratification and this list may be associated with purchase, 23. Property tax is imposed on real expanded in due course. holding and sale of securities, as property situated in Russia and well as the amounts taxed at owned by individuals. The tax rate depends on the value of the

International Assignment Taxation Folio 7

asset and varies from 0.1% to made to heirs in relation to an companies received by non- 2% of the registered value of the author’s remuneration for residents are taxed at 15%). property (which is normally inventions, arts, etc. If lower than market value). applicable, tax is paid in 28. The provisions of domestic law Helicopters, yachts and boats accordance with the rates as described in the preceding are also liable to this tax, and listed above. section are modified in some the amount varies according to instances by the application of the horsepower of the engine. Deduction of income double tax treaties and therefore Cars are subject to vehicle- tax at source it is necessary to give specific owner’s tax, which applies to consideration to the 26. Where an international assignee local and foreign corporate and circumstances of each particular is remunerated by a Russian individual vehicle owners. It is international assignee. legal entity or a foreign legal payable annually at rates per entity that has a branch or a horsepower depending on the Obligatory insurance representative office in Russia, vehicle’s engine capacity. contributions that entity will be required to (including state Land tax withhold income tax at source on amounts paid to that pension 24. Individuals owning or using employee. In case withholding is contributions) land in Russia are subject to impossible (i.e., if no payments 29. Unified Social tax is replaced by land tax. Rates of tax vary are made to the individual) the Obligatory Insurance depending on the location and tax agent is required to advise Contributions (OIC) with effect the quality of the land. the tax authorities and the from 2010. taxpayer of such impossibility, Inheritance and as well as the amounts due for All business units registered in gift-taxation withholding. The individual may Russia are required to make OIC then be issued a , 25. Inheritance and was with respect to their employees abolished in Russia as of 1 but even in cases when no and contractors. Remuneration, January 2006, however, assessment is issued he/she bonuses and other income paid personal income tax may be becomes personally liable for in cash and in kind accrued by payable by individuals receiving submitting a declaration and an employer in favor of property by way of gift, making the tax payment. employees are included in the taxable base. The OIC is depending on the type of the Taxation of non- property and its source. In case calculated for each individual. of a gift, personal income tax is resident individuals The OIC are the liability of the employer only; employees are generally payable with regard to In general the market value of gifts not liable to make any OIC. 27. The income of non-resident received from companies or individuals is liable to taxation In 2010-2011 OIC were not due organizations by individuals. only to the extent that it is with respect to expatriates With regard to the gifts received considered Russian sourced, temporarily staying in Russia. from individuals, taxable which, with respect to However, from 2012 their income includes houses, employment income, includes earnings are subject to OIC. apartments, country houses, all income related to an vehicles, securities and units of From 2012 a regressive scale individual’s activity performed investment funds with with uncapped level of OIC were in the territory of Russia. Non- exemption of transactions introduced. The rate applicable residents (except HQS and between close relatives to expatriates’ earnings within foreign nationals employed by (spouses, parents and children, the threshold of RUB 568,000 individuals for certain purposes) grandparents and (2013, subject to annual pay tax at the flat rate of 30% on grandchildren, brothers and indexation) is 22%. The Russian sourced income sisters). An inheritance is remuneration paid in excess of (dividends from Russian exempt from tax with an the threshold will attract an exception applying to payments additional 10% top up charge.

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There is exemption from OIC for The simplified procedure has such foreign specialists; the remuneration of HQS and made it possible to obtain the • foreign national employees work permit and visa invitation The work permits and work working in Russia on the basis letter within 14 working days of visas issued with respect to of labor contract(s) concluded the day of submission of such specialists shall be valid for a period shorter than 6 application to the Federal up to 3 years (instead of 1 year months in a calendar year. Migration Service and it may be with respect to regular foreign valid for the period up to employees); 30. The companies are obliged to 3 years. • pay Obligatory Accident The employment income of Insurance Contributions (OAIC) The other advantages of the HQS is taxed at 13% on mandatory social insurance above procedure are as follows: irrespective of residential against accidents at work (AI). status of individual; • The employer of highly Rates vary from 0.2% to 8.5% Remuneration paid to HQS is (of employees' compensation) qualified specialists shall be exempt from the obligation to not subject for Insurance depending on the employer's Contributions, however, activity. obtain migration quota for such specialists; Accident Insurance 31. The Russian Federation has Contributions are still payable. • The employer shall have a reciprocal social security agreements with the countries right to employ foreign highly listed in Appendix B, however, qualified specialists without in practice these agreements do employment permit; not provide any benefits as they • The employer shall have a are mainly based on local right to appraise the legislation which is currently not qualification of highly effective. qualified specialist by its own HQS migration and it will not be required (at least, it is not specified in the regime law) to provide to the 32. In 2010 Russian law introduced migration authorities with any simplified procedure of education certificates obtaining the work confirming the qualification of authorization documents for the foreign employees being the HQS. Please note that HQS regime cannot be used by representative offices of foreign legal entities but it may still be used by branches of foreign legal entities.

HQS is a foreign national who has work experience, skills or accomplishment in a particular area of activity and who works in Russia and whose annualized salary constitutes generally not less than RUB 2,000,000.

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Step 3: What to do before you arrive in the Russian Federation

Work permit although individual work stay in Russia for a maximum of permits are still required. 90 days during any period of 33. There are certain regulations 180 days. If a foreign national is which relate to work permits for Visas going to stay for over 90 days in expatriates. Generally, all total, he must leave Russia and 36. According to the applicable foreign employees have the right wait until the 180-day period Russian immigration legislation to be engaged in gainful has expired before re-entering the type of Russian entry visa employment in Russia only if the country. they hold individual work should correspond with the type permits and work visas. For the of activity performed by the Employment foreign national in Russia. Thus, employment of regular contracts employees (i.e. employees with for the purpose of going to the amount of salary less than 2 Russia on a business trip (e.g. to 39. The applicable Russian million RUB per year) conduct negotiations, conclude employment law provides that employers (e.g. Russian legal contracts, participate in employment contracts of entities, Branches/ conferences, etc.) a foreign foreigners working in Russia Representative offices of foreign visitor should obtain a Russian should not contain less legal entities) should hold business visa. Meanwhile, for favorable terms, than are employment permits (i.e. the purpose of performing provided under Russian permission for a company to employment activity (i.e. legislation. Additionally, attract foreign personnel). performing an employment employment contracts are function on a regular basis) a required to be executed at least 34. The procedure of obtaining foreign employee should obtain in Russian and in a written work authorization documents a work visa, which is subject to form. under standard (not HQS) prior obtaining a work permit. regime is rather slow and time 40. Foreign employees should consuming. According to our 37. «Business visas» can be issued conclude local employment practical experience the process either for a period of 3 months contracts to work in Russia, as can take approximately 4 – 4.5 (i.e. single or double entry visa) only local employment contracts months. It is worth mentioning or for a period of 1 year (i.e. and not secondment agreements that employment during the multiple entry visa). Russian can be the basis for obtaining pending period is not entry work visas are valid for the both employment and work permissible. period of validity of a work permits. permit (maximum for a period 35. There are some exceptions from of 1 year for regular employees Remuneration the general procedure with and up to 3 years for HQS). packages regard to obtaining work authorization documents for 38. Due to recent amendments to 41. While structuring an assignment foreign employees from visa free the Russian immigration to the Russian Federation, an regime countries (mostly legislation, rules with regard to employer should ensure that citizens from CIS-countries). An business and humanitarian visas satisfactory arrangements have employer is not required to were changed. Thus, a foreign been made for an expatriate to obtain employment permits to national having a multi-entry cover additional expenses that employ such foreign employees, business or humanitarian visa will be incurred as a result of (valid for a period of 1 year) can living in Russia. The cost of

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tobacco products are subject to quantity limitations.

46. Exemptions from these import charges may be available in some cases. In particular, goods designated for personal use with the value not exceeding EUR 1,500 (for air travel EUR 10,000) per person may be imported free of import taxes. The customs authorities are fairly stringent in assessing the validity of valuations put forward by the taxpayer. Small exemptions are also available for the import of cigarettes and alcohol for personal use.

living in the Russian Federation firearms but also a range of 47. More comprehensive is relatively high and Moscow is other goods including some exemptions are also available to currently an expensive city in types of foods, plants, animals, particular groups of which to live as an expatriate. fish and products derived from international assignees (i.e. endangered species. diplomatic personnel). Timing of arrival 44. For an international assignee, 48. PricewaterhouseCoopers Russia 42. An assignee should be advised temporary importation of has specialists in all aspects of to discuss the arrival or personal belongings to Russia customs charges on the departure date with the tax for personal use is generally not importation of personal adviser to minimize any liability limited but subject to possessions. Advice and to tax. This may be particularly declaration. As with all taxes calculations of the tax that will relevant where it is possible to and duties in Russia, the be assessable in a particular extend the number of days spent customs regime governing the situation can be provided on in Russia during the calendar importation of personal request. year over the residence possessions is subject to regular threshold of 183 days. change. It is therefore Transferring funds recommended that advice from to Russia Importing personal a shipping agent or professional 49. There are currently no legal or possessions customs/tax advisor concerning financial restrictions on the exact arrangements 43. Before arriving in Russia, an individuals who wish to transfer currently in force is obtained assignee should be aware that funds to Russia. If the total sum prior to arrival. the importation of certain items of money exceeds the equivalent may be prohibited or restricted. 45. The rates of import customs of USD 10,000, the currency This includes not only the more are relatively high. Certain should be declared. obvious items such as drugs and goods such as cars, alcohol,

International Assignment Taxation Folio 11

Step 4: What to do when you arrive in the Russian Federation

Notification of Tax returns and filing Setting up a bank Russian immigration 52. There is currently no account authorities on foreign requirement to submit 58. An assignee may open a bank nationals’ arrival preliminary tax declarations account in a foreign currency upon arrival in Russia. and in roubles with an 50. A hosting party (i.e. an authorized Russian bank. employer, who employ a foreign 53. Where an individual has income Normally, the procedure of employee in Russia, or a subject to tax in Russia from opening a bank account is housekeeper, who hosts a which Russian tax was not simple and straightforward. foreign national, etc.), should withheld at source at the correct notify local immigration rate, he/she is obliged to file a authorities on the foreign tax return no later than 30 April national’s arrival to Russia (i.e. of the following year to the to perform immigration designated tax inspectorate. Tax registration of the foreign is payable on the basis of the national). The notification submitted return no later than should be performed within 7 15 July. working days from the date of arrival for regular employee. 54. The legislation requires an HQS employees are exempted individual to submit tax returns from this requirement unless in Russian in a prescribed the period of their continuous format. staying in Russia is more than 55. Employers must notify tax and 90 days. For this purpose a labor authorities on concluding hosting party should file a an employment contract with a notification to the immigration foreign national. authorities personally or send it by post. The detachable part of 56. HQS shall be registered with the notification, bearing a stamp Russian tax authorities. of immigration authorities or post office, should be kept by Tax payments the foreigner during his stay in 57. The tax authorities are not Russia. obliged to issue tax assessments 51. If an assignee is going to stay in unless the amount of tax is a hotel, the hotel administration assessed in the course of a tax will act as a hosting party and audit of the tax return will notify the immigration conducted by a tax inspector. authorities on arrival and Tax must be paid in RUB only departure. by a taxpayer personally (either though a bank transfer or in cash), payments by companies on behalf of employees are not permitted.

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Step 5: What to do when you leave the Russian Federation

Tax return and filing Timing of departure restrictions are subject to frequent change. It is therefore 59. Generally where an individual 61. As in the case of arrangements advisable to check the has income subject to tax in for arrival, an assignee is requirements before departure. Russia from which Russian tax recommended to seek advice as was not withheld at source at to the most tax efficient date for Transferring the correct rate, he/she is departure from the Russian possessions abroad obliged to file a tax return no Federation. later than 30 April of the 63. Generally, export duties may be following year to the designated Transferring funds imposed on the transfer of tax inspectorate. Tax is payable abroad personal effects above a on the basis of the submitted specified value. Moreover, 62. Whereas bank transfers of funds return no later than 15 July. certain categories of goods are outside of Russia may be made However in the situation where subject to elaborate customs by foreign nationals practically an individual leaves Russia formalities. In particular, the without restrictions, there are permanently during the export of objects of culture and still limited restrictions for calendar year in respect of art generally requires prior foreign individuals on which a tax declaration is to be permission from the Ministry of transferring cash funds through submitted, such return should Culture. Taking into customs in the amount be filed one month before consideration regular changes in exceeding the equivalent of USD his/her permanent departure. Russian customs legislation we 10,000 out of Russia, e.g., the Tax is then payable on the basis recommend that you seek currency should be declared and of this declaration within 15 professional advice on the rules an individual may need to days after submission. applicable and the necessary present documents confirming procedures are obtained before Notification on early the origin of cash (either a departure from the Russian termination of the customs declaration or any Federation. other documents confirming employment contract import or transferring cash of a foreign national funds to Russia). These 60. In case of early termination of the employment contract of foreign national, the labor and tax authorities should be notified. Additionally it is required to cancel the work permit and work visa.

International Assignment Taxation Folio 13

Step 6: Other matters requiring consideration

Stock options company has an appropriate employee's pension license in RF and the insurance contributions to voluntary 64. Stock options are a quickly agreement only provides for licensed plans are tax deductible developing area for both payouts directly to the medical from the taxable base within the multinational and Russian provider and not to the insured limits established for social companies doing business in individual. deductions. Russia. However, currently there are no special rules for the For HQS the provision on Miscellaneous taxation of stock option plans voluntary medical insurance and their tax treatment is based should be included into 68. Although this folio primarily on the general provisions of the employment contract. deals with tax issues, it is law which may be subject to advisable to seek advice on the various interpretations. As such, Pensions following matters before generally an individual is taxed relocation to Russia: 66. Income from Russian state upon exercise of the option on pensions is not treated as • The availability of housing the difference between fair taxable income to the individual and the likely costs of market value of the shares at (currently, the statutory pension accommodation; exercise and the exercise price. age is 60 years for men and 55 The tax rules covering the sale of years for women but many • Education facilities for shares are as described groups of employees have a children, where appropriate; previously. right for early retirement which • The level of remuneration is usually 10 years earlier than Private medical required to provide a proper standard retirement age). insurance standard of living for the 67. Employer’s contributions to a assignee and family. 65. Sums paid by an individual for Russian insurance company private (voluntary) medical under pension insurance insurance are not tax deductible. agreements and to Russian Payments made by an employer licensed non-state pension fund for the medical insurance of an are not taxable for the employee or family members are employees, whereas the treated as non-taxable to the respective pension payments are employee if the insurance taxable. As of 1 January 2007 an

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Appendix A: Double-taxation agreements

Countries with which Algeria Indonesia Philippines Russia currently has Albania India Poland double-taxation Argentina Iran Portugal agreements: Armenia Ireland, Rep. of Qatar Austria Italy Rumania Australia Israel Saudi Arabia Azerbaijan Japan Serbia; Montenegro Belgium Kazakhstan Singapore Brazil Kyrgyzstan Slovak Republic Bulgaria Korea (South) Slovenia Belarus Kuwait South Africa Botswana Latvia Spain Canada Lebanon Sri Lanka China, P.R. Lithuania Sweden Chile Luxembourg Switzerland Croatia Macedonia Syria Cuba Malaysia Tajikistan Cyprus Mali Thailand Czech Republic Mexico Turkey Denmark Moldova Turkmenistan Egypt Morocco Ukraine Finland Mongolia United Kingdom France Namibia United States of America Germany Netherlands Uzbekistan Greece New Zealand Venezuela Hungary Norway Vietnam Iceland North Korea

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Double-taxation Estonia Georgia Oman agreements signed but Ethiopia Mauritius no yet effective:

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Appendix B: Social security reciprocal agreements

Reciprocal agreements Bulgaria Mongolia Spain have been concluded Czech Republic Romania with the following Hungary Slovak Republic countries but in general these agreements do not provide standard protection of obtaining social security benefits, thus, their applicability should be analyzed in each specific case:

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Appendix C: Russia contacts and offices

Contacts Offices

Karina Khudenko Moscow Moscow PricewaterhouseCoopers Russia B.V. White Square Business Center Tel: [7] (495) 967 6000 Butyrsky Val, 10 Fax: [7] (495) 967 6001 Moscow, 125047 Email: karina.khudenko@ Russia ru.pwc.com Tel: [7] (495) 967 6000

Fax: [7] (495) 967 6001 Gennady Odarich

Moscow Tel: [7] (495) 967 6000 Fax: [7] (495) 967 6001 Email: gennady.odarich@ ru.pwc.com

Evgeny Sivoushkov Moscow Tel: [7] (495) 967 6000 Fax: [7] (495) 967 6001 Email: evgeny.sivoushkov@ ru.pwc.com

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