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Russia rules on building sites as permanent establishments

March 19, 2009

A Turkish construction company has won a case in Russia over when a permanent establishment (PE) is created.

The Russian Federal Arbitration Court of the Far East Circuit (in Russian) said that the opening of a building site by a foreign company does not automatically create a PE. The court ruled that the tax authorities should rely on the relevant tax treaty to determine whether or not the site constitutes a PE.

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