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 the right to use of copyright to any work of literature, art or science, patent, trade mark, design,…