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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Russia: Independent personal services

Income derived by a United Kingdom resident in respect of professional services or other activities of an independent character are taxable only in the United Kingdom unless the individual has a fixed base regularly available to him in the Russian Federation.

If the latter circumstances apply, the Russian Federation is permitted to tax the income attributable to the fixed base in the Russian Federation (Article 14(1)).