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HMRC internal manual

Double Taxation Relief Manual

DT: Soviet Union: double taxation agreement, Article 6: Profits from commercial activities

(1) The profits derived by a resident of a Contracting State from carrying on commercial activities in the other Contracting State other than through a permanent establishment shall not be taxable in that other State. If the resident derives profits from commercial activities through a permanent establishment situated in that other State those profits may be taxed in that State but only so much of them as is attributable to the activities of the permanent establishment.
(2) In determining the profits derived by a resident through a permanent establishment, there shall be deducted expenses which are incurred for the purposes of the permanent establishment, including management and general administrative expenses, whether incurred in the State in which the permanent establishment is situated or elsewhere.
(3) No profits shall be attributed to a permanent establishment by reason of the mere purchase of goods or merchandise for the resident.

(4) Where profits include items of income which are dealt with separately in other Articles, then the provisions of those Articles shall not be affected by the provisions of this Article.