Russia Clarifies Gains from Alienation of Shares Not Taxable under Tax Treaty with Germany
The Russian Ministry of Finance recently published letter No. 03-08-05/10953 concerning the taxation of gains from the alienation of shares in a Russian company by a German resident. The letter notes that under the Russian Tax Code, a non-resident will be subject to tax on its Russian source income if it has a permanent establishment in Russia. If it does not have a permanent establishment in R…
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