The Russian Permanent Establishment: A Trap for Foreign Distributors?

The author discusses the Oriflame decision, which held that both a tax deduction for licence fees and input VAT should be denied, as Oriflame OOO was the PE of its Luxembourg grandparent company. The case is discussed from an international perspective considering, inter alia, OECD Action Point 7 on preventing the artificial avoidance of PE status.