It refers to the situation when a Russian organization buys services from a foreign company, and Russia being recognized as the place of sale for the purposes of VAT calculation.

Payment in favor of a foreign organization is made by a payment intermediary.

In this case, the Russian company is recognized as a tax agent regardless of how the payment was made. Russian company is obliged to calculate and pay VAT.

This explanation was given by the Ministry of Finance of Russia in a letter dated 05.05.2025 N 03-07-08/44734.

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