When A Foreign Company Is Not Profit Tax Agent

If a foreign company has only a branch office in Russia and pays a foreign company (including Belorussian) for services rendered outside of the Russian Federation, the contracting company will not be a  Profit Tax agent. The Moscow tax authorities announced this in a letter dated July 22, 2009 № 16-15/062923.

The basis for this conclusion is that income received as a result of a foreign contractor rendering services outside of the RF is not subject to the Profit Tax in Russia (Chapter 25 of the Tax Code of the RF).