On 6 June 2013, the Ministry of Finance made a public Letter No. 03-08-05/19889 clarifying the taxable income of a Kazakh company performing activities through a branch. The Kazakh company was building a plant in Russia where mineral resources will be processed in order to be sold in Russia. According to the article 5 of the Russia-Kazakhstan Income and Capital Tax Treaty (1996), the term "permanent establishment" comprises a construction site or construction, installation or assembly facility or services associated with monitoring the performance of those operations provided such site or facility exists for more than 12 months or such...