Russia's Ministry of Finance has released a guidance letter clarifying the criteria for determining whether a Russian resident enterprise has a permanent establishment in Azerbaijan under the countries' tax treaty. In Guidance Letter 03-08-05/8307, the MOF noted that the tax liability of a taxpayer in Russia (whether resident or non-resident) must be determined in light of the provisions of any applicable tax treaty (or treaty protocol) to which Russia is a party, and that those provisions pr…