Russia's Ministry of Finance recently issued Guidance Letter 03-08-05/21033, which clarifies that taxation rights on "other income" as set out in Article 21 (Other Income) of the 1983 income and capital tax treaty with Luxembourg. Under the treaty as originally signed, other income derived by a resident of a Contracting State that is not covered in the preceding Articles of the treaty will be taxable only in that State, wherever the income arises. However, the 2011 protocol to the treaty added a paragraph to Article 21 that states that such other income arising in the other Contracting State may be...