In its private ruling No. 03-08-02 of 24 July 2006, the Ministry of Finance clarified the definition of a permanent establishment under the provisions of the tax treaty between Russia and Austria, which is identical to the definition of a permanent establishment under the OECD 2005 Model.. Under the clarification, supervisory activity of a non-resident supplier of machinery regarding the installation thereof may constitute a PE even if the installation of machinery is carried out exclusively by the resident purchaser of the machinery. Although the Ruling does not apply directly to other tax treaties, it indicates the position take by...