On 07 February 2013, the Ministry of Finance issued Letter No. 03-08-13 clarifying whether a limited liability partnership (LLP) incorporated under the UK legislation may be considered a person for the purposes of the Russia - United Kingdom Income Tax Treaty (1994) (the Treaty). According to article 1 of the Treaty, persons who are residents of Russia or the UK or of both states may claim the Treaty benefits. Also, article 3 of the Treaty specifies that the term "person" comprises an individual, a company and any other body of persons, but does not include a partnership. The fact that the partnerships...