The Russian Ministry of Finance has published Letter No. 03-08-05/61066 of 28 August 2018, which clarifies the application of the provisions of the 1996 tax treaty with Germany in relation to the deduction of advertising expenses by a Russian company that is 28% held by a German resident. The letter notes that under the Russian Tax Code, advertising expenses are fully deductible when incurred for advertising through mass media and telecommunications networks, for outdoor advertising, and in c…