The Russian Ministry of Finance recently published Letter No. 03-12-11/5639 concerning the determination of tax residence. Under the Russian Tax Code, a foreign company may be determined to have its tax residence in Russia if its place of management is deemed to be in Russia. For this purpose, place of management may be deemed to be in Russia if:
- The foreign company's executive body regularly carries out its company-related activities in Russia, unless such activities are carried out at a si…