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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Soviet Union: double taxation agreement, Article 3: General definitions

(1) In this Convention:
(a) the term `United Kingdom` means the territory of Great Britain and Northern Ireland;
(b) the terms `Union of Soviet Socialist Republics` and `USSR` mean the territories of all the Union Republics;
(c) the term `Contracting State` means the United Kingdom or the USSR, as the context requires;
(d) the term `person` means an individual and:

(i) in relation to the United Kingdom, also a company or any body corporate or any other entity which is treated as a body corporate for the purposes of taxation in the United Kingdom;
(ii) in relation to the USSR, also any legal person or other organisation created under the laws of the USSR or any Union Republic and treated as a legal person for the purposes of taxation in the USSR;

(e) the term `resident of a Contracting State` means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. This term does not include any person who is liable to tax in that Contracting State only if he derives income from sources therein;
(f) the term `international traffic` means any transport by ship, aircraft, motor vehicle or railway operated by a resident of a Contracting State except when the transport is operated solely between places in the other Contracting State;
(g) the term `technical specialists` means individuals employed in the provision of expert services of any kind and includes physicians, scientists, lawyers, accountants, architects, engineers and personnel performing training and supervisory activities;
(h) the term `competent authority` means:

(i) in the case of the United Kingdom, the Board of Inland Revenue or their authorised representative;
(ii) in the case of the USSR, the Ministry of Finance of the USSR or their authorised representative.

(2) As regards the application of this Convention by the Contracting States any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of the Contracting State levying the taxes which are covered by this Convention.