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HMRC internal manual

Double Taxation Relief Manual

Soviet Union: Dividends, interest and royalties

Dividends, interest and royalties received by a resident of the United Kingdom are exempt from Soviet Union tax provided that the resident is and has been present in the United Kingdom during the period to which the dividend relates or the period of accrual of interest or the period in which the royalties arise.

The exemptions are not given if the dividends, interest or royalties are effectively connected with (see INTM153110 fifth sub-paragraph) a permanent establishment which the United Kingdom resident recipient has in the Soviet Union.