Treaty between Russia and Bulgaria – Russian MoF clarifies that tax withheld not in accordance with the tax treaty cannot be credited in Russia

Recently, the Ministry of Finance published Letter No. 03-03-06/4/44331 issued on 23 October 2013 clarifying whether corporate income tax withheld by a Bulgarian branch belonging to a Russian company could be credited against the corporate income tax liabilities in Russia.

A Russian company, member of a consolidated group of taxpayers, registered a branch in Bulgaria, which acquired engineering services from another Russian company, a member of the same consolidated group. The Bulgarian br…