The Russian Ministry of Finance recently published letter No. 03-08-05/10953 concerning the taxation of gains from the alienation of shares in a Russian company by a German resident. The letter notes that under the Russian Tax Code, a non-resident will be subject to tax on its Russian source income if it has a permanent establishment in Russia. If it does not have a permanent establishment in Russia, a non-resident will be subject to tax on certain types of specified income, including gains f…