OrbitaxRussian Ministry of Finance clarifies provisions of a tax treaty between Russia and Austria
|Treaty Development|Russia-Austria
In its private ruling No. 03-08-02 of 24 July 2006, the Ministry of Finance clarified the definition of a permanent establishment under the provisions of the tax treaty between Russia and Austria, which is identical to the definition of a permanent establishment under the OECD 2005 Model..
Under the clarification, supervisory activity of a non-resident supplier o…
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