The Russian Ministry of Finance recently published guidance letter 03-08-05/64903 of 12 August 2021 regarding the scope of the application of the 2014 income tax treaty with China. The letter notes that in accordance with subparagraph (b) of paragraph 1 of Article 3 of the tax treaty, the term "China" means the People's Republic of China (PRC) and, when used in a geographical sense, means the entire territory of the PRC, including its territorial sea, which is subject to Chinese tax laws, as …