OrbitaxTreaty between Russia and Ukraine – Russian MoF clarifies that payments for the use of computer programmes qualify as royalties
|Treaty Development|Russia; Ukraine
On 18 October 2013, the Russian Ministry of Finance issued Letter No. 03-08-05/43638 clarifying the tax treatment applicable to payments made for the use of computer programmes by a Russian company to a Ukrainian company.
Based on article 12 of the Russia - Ukraine Income and Capital Tax Treaty (1995), the term royalties include payments of any kind received as a remuneration for the use or …
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