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HMRC internal manual

Double Taxation Relief Manual

DT: Soviet Union: double taxation agreement, Article 7: Profits from international traffic

(1) Profits derived by a resident of a Contracting State from international trafficshall be taxable only in that State.

(2) The provisions of paragraph (1) of this Article shall also apply to profits from theparticipation ina pool, a joint business or an international transport operating agency.