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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Russia: interest

Interest arising in the Russian Federation and paid to a resident of the United Kingdom who is the beneficial owner of the interest is taxable only in the United Kingdom (Article 11(1)), except where the interest is effectively connected (see INTM153110) with a permanent establishment or fixed base which the United Kingdom resident recipient has in the Russian Federation.

In the latter circumstances the provisions of the Business Profits Article (Article7) or the Independent Personal Services Article (Article 14) will apply.