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Treaty between Russia and United States – Russian Ministry of Finance clarifies application of treaty re deduction of certain expenses incurred for purposes of PE

08 February 2008

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Treaty Development

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Russia-US

Details of the clarification of 26 June 2007 of the Russian Ministry of Finance regarding the deduction of expenses incurred for the purposes of a permanent establishment (PE) of a US company situated in Russia have become available. The US company in question carries on business through a PE (a building site) in Russia. The US company rents apartments from a Russian company and then lease them free of charge to its foreign employees working in Russia. To furnish those apartments, the US company purchased furniture and appliances. The issue was whether the furnishing expenses incurred by the US company...