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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Soviet Union: double taxation agreement, Article 8: Dividends

(1) Dividends paid by a resident (in the case of the United Kingdom, a company) of a Contracting State, which are beneficially owned by a resident of the other Contracting State who is and has been present in that other State during the period to which the dividend relates shall be exempt from any tax in the first-mentioned State which is chargeable on dividends in addition to the tax chargeable in respect of the profits or income of the resident (in the case of the United Kingdom, the company).
(2) The term `dividends` as used in this Article shall have the meaning which it has under the taxation law of the Contracting State of which the person (in the case of the United Kingdom, the company) paying the dividend is a resident and shall include any item which is treated under that law as a dividend or distribution.
(3) The provisions of paragraph (1) of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on commercial activities in the other Contracting State through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with that permanent establishment. In such a case, the provisions of Article 6 shall apply.