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HMRC internal manual

Double Taxation Relief Manual

Soviet Union: Artistes and athletes

All income derived by a resident of one country from performances as an artiste, athlete or sportsman in the other country is taxable only in the country of which the recipient is a resident (Article 14).

This provision is in total contrast to Article 17 of the OECD Model Convention (see INTM159030) which is found in most of the United Kingdom’s double taxation agreements.