According to the Germany-Russia Income and Capital Tax Treaty, the Finance Ministry has declared a Letter 03-08-RZ/38351 describing the tax treatment applicable to royalties paid by a Russian resident to a German limited liability partnership and was issued on August 4, 2014. The MoF figured out that a limited liability partnership created on the basis of the German legislation is not deemed to be a separate legal person. If tax residence certificate for all the partnership members are submitted with a document to the Russian payer together confirming that the income is taxed in Germany then according to the Tax Treaty, a limited liability partnership formed under the German legislation may claim release in Russia.
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