OrbitaxTreaty between Russia and Kazakhstan – Russian MoF clarifies taxable income obtained by a Kazakh branch
|Treaty Development|Kazakhstan; Russia
On 6 June 2013, the Ministry of Finance made a public Letter No. 03-08-05/19889 clarifying the taxable income of a Kazakh company performing activities through a branch. The Kazakh company was building a plant in Russia where mineral resources will be processed in order to be sold in Russia.
According to the article 5 of the Russia-Kazakhstan Income and Capital Tax Treaty (1996), the term …
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