Russia's Federal Tax Service issued Guidance Letter GD-4-3/3665, which clarifies the tax treatment of non-resident income from the sale of shares of a Russian legal entity when the non-resident has no permanent establishment in Russia.
The main rule for non-residents is that Russian sourced income is taxable. This includes income from sources in Russia for the sale of shares of a Russian legal entity where more than 50% of the Russian entity's assets consist of immovable property located in Russ…