The Russian Ministry of Finance recently released Guidance Letter No. 03-08-09/96760, which clarifies the taxation of payments for the operation of shipping vessels in international transport under the 1997 tax treaty with Turkey. The letter explains that under subparagraph 8 of paragraph 1 of Article 309 of the Russian Tax Code, income from international transportation is included in the income of a foreign organization subject to income tax withheld at the source of payment in Russia. However, as per paragraph 1 of Article 7 of the Tax Code, where a tax treaty is in force with the country of residence...