The Russian Ministry of Finance recently published guidance letter 03-08-05/64903 of 12 August 2021 regarding the scope of the application of the 2014 income tax treaty with China. The letter notes that in accordance with subparagraph (b) of paragraph 1 of Article 3 of the tax treaty, the term "China" means the People's Republic of China (PRC) and, when used in a geographical sense, means the entire territory of the PRC, including its territorial sea, which is subject to Chinese tax laws, as well as any area beyond its territorial sea in respect of which the PRC, in accordance with...