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 busine…
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