Letter of the Ministry of Finance #03-07-РЗ/19611 from April 25, 2014, answered a question regarding the place of supply of services offered by a foreign contractor to a Russian organization for data storage on a server located abroad.
The Russian Tax Code establishes a list of cases when Russia is recognized as place of supply of services for VAT purposes. This list does not include Russia as a location of business activity of an acquiring company. However, this does not apply to all services, but only those directly listed in the Tax Code (information processing services, lease of movable property, except for land motor vehicles, etc.) The list does not name data storage services directly.
Therefore, the place of supply of services for storage of data on servers located outside of Russia is established based on the location of company caring out the abovementioned services (a foreign contractor). Since Russia is not recognized as a place of supply of services, these services are not subject to VAT.
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