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Russia Clarifies Foreign Exchange Gain/Loss Treatment of PE under French Tax Treaty

|Treaty Development|Russia-France
Russia-France

The Russian Ministry of Finance recently published Letter No. 03-07-03/47566, which clarifies the tax treatment of foreign exchange gains/losses of a French resident's permanent establishment (PE) in Russia.

As provided under Article 7 (Business Profits) of the 1996 France-Russia tax treaty, if an enterprise of one Contracting State carries on business in the other State through a permanent …

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