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Russia Clarifies that Foreign Tax Credit not Available for Corporate Tax Withheld due to Misapplication of the Tax Treaty with Kazakhstan

|Treaty Development|Russia-Kazakhstan
Russia-Kazakhstan

The Russian Ministry of Finance recently issued Guidance Letter 03-08-05/45365, which clarifies whether a Russian taxpayer is eligible for a foreign tax credit for corporate tax withheld in Kazakhstan despite not having a permanent establishment in the country.

According to the letter, although Russia provides a tax credit under domestic law for foreign tax paid, for Kazakh-source income, the…

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