Russia's Ministry of Finance recently published Letter no. 03-08-05/97816 of 13 December 2019 concerning the taxation of the alienation (sale) of exclusive rights to intellectual property (IP) by a non-resident entity in Russia. The letter notes that the income received as compensation for the use of or the right to use IP rights in Russia falls within the scope of Russia source income and is subject to tax at source. Income received by a non-resident from the sale of exclusive rights in full…