The Russian Ministry of Finance recently published Letter No. 03¬08¬05/25712, which clarifies the offset of foreign taxes paid by Russian resident companies. The Letter is summarized as follows.
According to Article 311 of the Tax Code, the amount of tax paid/withheld in accordance with the laws of a foreign country may be offset against Russian tax due, with the offset limited to the amount of Russian tax that would have been payable on such income. In order to claim the offset, the taxpaye…