The Russian Ministry of Finance issued Letter No. 03-07-08/62571 confirming that the VAT treatment of client search services rendered by a Russian supplier to a non-resident company under an agency agreement is considered to have the place of supply where the service has been provided (Russia), and should be therefore subject to Russian VAT.
According to article 146 of the Tax Code, VAT is levied on the goods, works and services supplied on the Russian territory. Pursuant to section 1(5) of article 148 of the Tax Code, works and services not directly mentioned in section 1-4.1, 4.4 of article 148 of the Tax Code are generally deemed to be supplied in Russia, provided the supplier has a place of activity in Russia. Because agency services are not directly mentioned in article 148 of the Tax Code, the place of supply of these services is the place of the supplier’s activity.
If you have any questions, please feel free to contact my colleague Vladimir Konstantinov on firstname.lastname@example.org or +749 596 762 36.
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