The Ministry of Finance has explained the issue of personal income taxation for individuals working outside of Russia in Letter #03-04-06/6-158 dated 07.23.2010. It was based on the particular example of a Russian state unitary enterprise that employs a Spanish citizen, whose permanent place of residence is Venezuela, where he also performed the work in question. In this case, the commercial services contract represents the enterprise’s interests in Venezuela, and not Spain.
The Letter notes that the object of personal income taxation is the income received by the Russian tax residents either from sources in Russia or from sources outside of Russia; but for individuals who are not residents for tax purposes – only from sources in Russia.
Compensation for labor or fulfillment of other duties, for performing work, rendering services, or for performing activities outside of Russia is considered, for tax purposes, income received from sources outside of Russia.
Since, in the situation being examined, the individual is rendering services in a foreign country that he lives in, the compensation he receives is not considered income from a source within Russia. By this logic, if an individual is not considered to be a resident of Russia for tax purposes, then their income from foreign sources is not subject to taxation in Russia.
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