Treaty between Russia and Bulgaria – Russia MoF clarifies whether taxes paid in Bulgaria may be credited against corporate income tax liabilities in Russia

On 12 March 2013, the Ministry of Finance issued Letter N 03-08-05/7342 clarifying the procedure for crediting in Russia the tax paid abroad.

A Russian company registered a branch in Bulgaria for performing activities. The branch acquired engineering services from another Russian company (the Contractor), which was not registered for tax purposes in Bulgaria. When remitting payments for the Contractor's services, the branch acted as a tax agent and withheld corporate income tax at a rate…