The Russian Ministry of Finance recently issued Guidance Letter 03-08-05/45365, which clarifies whether a Russian taxpayer is eligible for a foreign tax credit for corporate tax withheld in Kazakhstan despite not having a permanent establishment in the country. According to the letter, although Russia provides a tax credit under domestic law for foreign tax paid, for Kazakh-source income, the provisions of the Kazakhstan-Russia tax treaty apply. In the treaty's provisions for double taxation relief, Russia will allow a credit for income or capital that may be taxed in Kazakhstan under the provisions of the treaty. However, because the provisions of...