Treaty between Russia and Italy – Russia MoF clarifies whether consultancy, supervision and control services performed in relation to an installation project may create a permanent establishment in Russia

On 20 March 2013, the Ministry of Finance issued Letter No. 03-08-05/8706 clarifying whether consultancy, supervision and control services performed by Italian specialists in relation to an installation project developed in Russia would trigger a permanent establishment exposure for the Italian specialists in Russia.

The Ministry of Finance referred to the definition of the permanent establishment provided for in article 5 of the Italy - Russia Income and Capital Tax Treaty (1996), where…