The Russian Ministry of Finance has issued Letter No. 03-12-11/1/26759 on the conditions for a credit for foreign tax paid on foreign source income. The letter clarifies that in order for a foreign tax credit to apply, two main conditions must be met:
- The taxpayer has included the foreign source income in its tax base for Russian corporate tax purposes; and
- The corporate tax was in fact paid or withheld in the foreign country.
To prove that the second condition is met, the taxpayer must o…