An income tax treaty between Brazil and Russia has been ratified in Brazil when, on 1 August 2017, a presidential decree was published in the official gazette.
The income tax treaty (signed in 2004) includes provisions regarding permanent establishments (PEs) that are a building site, construction, assembly or installation project or that concern connected supervisory activities—the PE status is determined with reference to a period of nine months.
The Brazil-Russia income tax treaty has a professional services article, focused mainly at independent activities of scientific, literary, artistic, educational as well as independent activities of doctors, lawyers, architects, dentists and accountants. The income of such individuals is to be taxed at their country of residence (with certain exceptions, such as payments made by residents of the other contracting state and/or PEs for activities are rendered in the other contracting state for a period of more than 183 days in a 12-month period).
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