Corporate income tax : liability to tax.

Taxation of income of a foreign company depends on whether the company has a permanent establishment in the Russian Federation. The factors used to determine, for tax purposes, whether a foreign company has a permanent establishment in Russia are defined in the Tax Code and tax treaties and normally include:

- a branch of the foreign company, office, bureau, construction or building area or any other place of business activity;
- any Russian resident (a person or a company) representing the foreign entity who has the authority to conclude contracts in the name of the foreign corporation and normally exercises it if this activity is not part of usual business.

The tax code's definition of a permanent establishment complies with the model OECD double tax treaty and contains a list of activities that do not constitute a taxable presence.

 

 

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