16.02.10

If a foreign company has only a branch office in Russia and pays a foreign company (including Belorussian) for services rendered outside of the Russian Federation, the contracting company will not be a  Profit Tax agent. The Moscow tax authorities announced this in a letter dated July 22, 2009 № 16-15/062923.

The basis for this conclusion is that income received as a result of a foreign contractor rendering services outside of the RF is not subject to the Profit Tax in Russia (Chapter 25 of the Tax Code of the RF).

Translated by Alinga Consulting Group.

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