The Russian Ministry of Finance has issued a letter explaining taxation procedures for any payment by Russian company to a foreign organization for non-exclusive rights to use an item of intellectual property (in this case, specifically a TV commercial).
The Letter points out that the payment to a foreign company in accordance to the commissioning agreement is taxed at the source of payment in the Russian Federation.
For purposes of taxation in this case, priority is given to the article “Royalties” (“Profits from Copyrights and Licenses”, etc.) of the appropriate agreements on double taxation, if applicable.
This is according to Letter № 03-03-06/1/482 of the Ministry of Finance of the Russian Federation from August 12, 2011
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