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Russia Clarifies PE Criteria Under Tax Treaty with Azerbaijan

|Treaty Development|Russia-Azerbaijan
Russia-Azerbaijan

Russia's Ministry of Finance has released a guidance letter clarifying the criteria for determining whether a Russian resident enterprise has a permanent establishment in Azerbaijan under the countries' tax treaty. In Guidance Letter 03-08-05/8307, the MOF noted that the tax liability of a taxpayer in Russia (whether resident or non-resident) must be determined in light of the provisions of any…

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