The Russian Ministry of Finance recently published a guidance letter concerning whether the 1993 Russia-Sweden tax treaty covers the simplified tax regime. The simplified tax regime is available for smaller taxpayers meeting certain conditions and includes a single tax in place of other taxes including corporate income tax, individual income tax, property tax, and VAT. The letter notes that Article 2 (Taxes Covered) of the treaty includes that the treaty covers Russian income taxes and property taxes, as well as identical or similar taxes introduced after the treaty was signed. Although the single tax under the simplified regime effectively replaces...