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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Soviet Union: double taxation agreement, Article 1: Scope of the Convention

(1) This Convention shall apply to persons who are considered to be residents for taxpurposes of one or both of the Contracting States.
(2) This Convention extends to the territory of each Contracting State and to those areasof the Continental Shelf adjacent to the outer limit of the territorial sea of each Stateover which it exercises, in accordance with international law, sovereign rights for thepurpose of exploration and exploitation of the natural resources of such areas.
(3) In this Convention references to either of the Contracting States shall be treated asincluding references both to the territory of the State concerned and to those areas ofthe Continental Shelf adjacent to the outer limit of the territorial sea of that Statewhich are mentioned in paragraph (2) of this Article.