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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Guidance by country: Russia: capital gains

Article 13 of the agreement provides source state taxing rights over gains arising to a resident of either the United Kingdom or the Russian Federation from the disposal of immovable property, as defined in Article 6 (Article 13(1)). This does not affect the rights of the residence state to tax the gains as well.

Where a resident of one of the countries disposes of shares (other than shares quoted on an approved Stock Exchange) deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other country, any gain arising may similarly be taxed in both countries if their respective domestic laws permit (Article 13(2)).

`Quoted on an approved stock exchange’ means listed at a price. This excludes shares listed on the United Kingdom stock exchange official list for which price quotes have been withdrawn and shares dealt in on an overseas exchange which uses an order driven rather than a quote driven system. Refer cases of doubt or difficulty to the Tax Treaty Team.