ersons, state structures and (or) executive powers of local government of treaty obligations;
Other similar incomes (subitem 10 of item 1 of item 309 NK the Russian Federation). 20 %
IMPORTANT: in subitem 10 of item 1 of item 309 NK the Russian Federations among incomes of the foreign organization of sources in Russia, are specified «other similar incomes». In methodical recommendations to tax departments on application of separate positions of chapter 25 of the Tax code of the Russian Federation, concerning features of the taxation of profit (incomes) of the foreign organizations (utv. By the order of the Ministry of Taxes and Tax Collection of the Russian Federation from 3/28/2003 N БГ-3-23/150), it is specified that analogousness of incomes consists not in their similarity with any of the types of income named in point 1 of article 309, and that they concern incomes of sources in the Russian Federation, not connected with activity through permanent mission, except for the incomes directly mentioned in article 309 as not concerning incomes of sources in the Russian Federation.
In particular, incomes of realization concern such incomes in territory of the Russian Federation of the goods imported from abroad on the terms of contracts of trading intermediary of the foreign organizations with the Russian organizations and citizens.
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