The Russian Ministry of Finance recently published Letter No. 03-08-05/21229, which clarifies the tax treatment of income derived by a Russian legal entity from the rendering of consulting services involving the drafting of technical documentation for a resident of Kazakhstan. The letter notes that under the Russian Tax Code, foreign source income is subject to tax in Russia, which may be offset with a credit for foreign tax paid. However, as per Article 7 of the 1996 tax treaty with Kazakhstan, business profits of the Russian entity will only be taxable in Russia unless the income is attributable to a...