Taxes and Taxation
Reference:
.
Specific conflicts and collisions appearing
when calculating and paying the tax
for profit by the foreign legal persons
// Taxes and Taxation.
2008. ¹ 11.
URL: https://en.nbpublish.com/library_read_article.php?id=56081
. Specific conflicts and collisions appearing
when calculating and paying the tax
for profit by the foreign legal persons
Abstract:
In the author’s opinion, the key criterion for qualification of the activities of the foreign organization in the Russian Federation, as preformed through the permanent representative office, is regularity of activity. The national legislation of the Russian Federation recognizes the preparation and supportive activities of the foreign organizations, as regularly performed through the office, as forming the permanent representative office.
The author considers, that the tax on profit of organizations for the foreign organizations, acting through their permanent representative offices is not set properly, namely, for the foreign taxpayers the law does not define the object of taxation.
|