Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter

Russia-United Kingdom

Responsive image

Russia Clarifies Existence of a PE under Tax Treaty with the UK

The Russian Ministry of Finance recently published Letter No. 03-08-05/36799 of 14 June 2017 concerning the existence of a permanent establishment of a UK company's representative in Russia under the 1994 income and capital tax treaty between the two countries. In accordance with paragraph 1 of Article 5 (Permanent Establishment), the term "permanent establishment" means a fixed place of business through which an enterprise of a Contracting State wholly or partly carries on business in the other Contracting State. According to the letter, this includes the following conditions:

  • The existence of a place of business, that is, premises or equipment;
  • The place of business is fixed, that is, established in a certain place with a certain degree of permanence; and
  • Commercial activity of the enterprise is implemented through the permanent establishment, meaning that persons who are in some way dependent on the enterprise (personnel) carried out the enterprise's activity in the State through the fixed place of business.

The letter provides that the term "place of business" means any premises, facilities, equipment or installations used for the business enterprise, regardless of whether they are used exclusively for this purpose or not. Place of business may also exist without separate premises, and only requires that sufficient space be available. Also, the commercial activity does not have to be of a productive nature and does not have to be constant, that is carried out without interruption in operations, but the operations must be regular.

Lastly, the letter notes that If the foreign company carries out activities in the Russian Federation of a preparatory and (or) auxiliary character for the benefit of third parties resulting in the formation of a permanent establishment, and there is no compensation provided for such activity, the tax base is determined at the rate of 20% of the expenses of the permanent establishment associated with such activities as per paragraph 3 article 307 of the Russian Tax Code.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

FX Rates

Global FX Rates including Tax year Average FX Rates and Spot Rates for all Reporting Currencies.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More