Russia's Federal Tax Service (FTS) recently published Letter No. SD-4-3/26956@ of 27 December 2019 concerning the taxation of the sale of real estate situated in Russia by a non-resident legal entity.
The letter includes that the income from such sales is considered Russian source income and the recipient is recognized as a corporate taxpayer. Where the income is not connected to a permanent establishment in Russia, it is subject to withholding at source. In determining the tax base, the re…