On 6 June 2013, the Ministry of Finance made a public Letter No. 03-08-05/19889 clarifying the taxable income of a Kazakh company performing activities through a branch. The Kazakh company was building a plant in Russia where mineral resources will be processed in order to be sold in Russia.
According to the article 5 of the Russia-Kazakhstan Income and Capital Tax Treaty (1996), the term "permanent establishment" comprises a construction site or construction, installation or assembly fa…