Details of the opinion of the Russian Supreme Arbitral Court of 27 November 2007 on the issue of permanent establishment in respect of corporate property tax have become available.
(a) Facts. A Turkish entity carried on construction projects in Russia for a period shorter than 18 months. Under Art. 5(3) of the Russia-Turkey tax treaty, such a construction project does not qualify as a permanent establishment. However, under the Russian Tax Code, a permanent est…