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 of machinery regarding the installation thereof may constitute a PE even if the installation of mac…