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So, according to article 246 NK the Russian Federation the foreign organizations receiving incomes of sources in the Russian Federation, admit tax bearers of the profit tax the Russian Federation.

Thus the duty by definition of the sum of the tax, deduction of this sum to tax transfer in the budget is assigned to the Russian organization (the tax agent), paying the specified income of the foreign organization (item 4 of item 286 NK the Russian Federation).

According to article 247 NK the Russian Federations object of the taxation under the profit tax for the specified category of the organizations admit the incomes received from sources in the Russian Federation and defined according to article 309 NK the Russian Federation.

In point 1 of article 309 NK the Russian Federations are established the types of income received by the foreign organization (in a case if reception of such incomes is not connected with enterprise activity of the foreign organization through permanent mission in the Russian Federation) which concern incomes of the foreign organization of sources in the Russian Federation and are subject to the taxation, kept at a source of payment of incomes in an order established by article 310 NK the Russian Federation.

The income name (item 1 of item 309 NK the Russian Federation) the Rate (item 284 NK the Russian Federation)

The dividends paid to the foreign organization -

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