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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Soviet Union: Employment etc income

The dependant personal services article (Article 13) covers not only remuneration from an employment exercised by a resident of one country in the other country but also income for services rendered by technical specialists (defined in Article 3(1)(g)).

The normal conditions for exemption (see INTM153170) from the other country’s tax on employment income apply, namely presence in the other country for a period or periods not exceeding 183 days in the fiscal year etc, and the income of a technical specialist is exempt if he is present in the other country for a period or periods not exceeding 365 days in two consecutive fiscal years.

In addition a resident of one country is exempt from the other country’s tax on remuneration from an employment exercised in, or income for services rendered in, the other country if the employment is exercised or the services are rendered

a) in connection with a building site, construction or assembly project in the other country not lasting more than 24 months,

b) for a permanent establishment in the other country of an air transport undertaking effectively managed in the first country,

c) aboard a ship, aircraft etc in international traffic if the effective management of the operator is in the first country, or

d) as a press, radio or television reporter or correspondent and the remuneration is derived from a source outside the other country.

These exemptions apply without any limitation of the time spent in the other country (Article 13(3)).