If a Russian company offers services associated with the organization of exhibitions in Russia for advertisement purposes to foreign companies which are not registered in Russia, these services are not considered taxable activity. This is according to the Letter of the Ministry of Finance #03-07-08/21 from February 1, 2012.
The Ministry explains that, for tax purposes, such services must be accounted for as advertising services.
In these cases, the place of supply for the advertising services is determined according to location of the customer purchasing these services.
Therefore, if customer is a foreign organization acting on the territory of a foreign country, then Russia is not considered as place of supply of these services.
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