The Russian Ministry of Finance recently published Letter No. 03-07-03/47566, which clarifies the tax treatment of foreign exchange gains/losses of a French resident's permanent establishment (PE) in Russia.
As provided under Article 7 (Business Profits) of the 1996 France-Russia tax treaty, if an enterprise of one Contracting State carries on business in the other State through a permanent establishment, the other State may tax the profits attributed to the PE. Based on Article 7 of the t…