In some cases a foreign company’s activity in Russia leads to a permanent establishment creation. For example:
- having a brunch in Russia
- storage of goods in warehouses in Russia
- work on a construction site etc.
Note!
If a foreign company’s activity in Russia meets the permanent establishment, such foreign company must register as a CIT payer in Russia.
The CIT rules are very complex.
Moreover, the DTT rules must be used. In 2021, Russia has 84 double taxation treaties with other countries.