The Russian Ministry of Finance has published Letter No. 03-08-05/43512 of 25 May 2020, which clarifies the taxation of payments made to a non-resident legal entity with a permanent establishment (PE) in Russia. The letter notes that in accordance with the Russian Tax Code, non-resident legal entities operating in Russia through a PE and (or) receiving income from Russian sources are recognized as taxpayers in Russia.
Where income is paid to a non-resident legal entity subject to tax in Russ…