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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 11: Income from immovable property

(1) Income derived by a resident of a Contracting State from the direct use, letting or use in any other form of immovable property situated in the other Contracting State may be taxed in that other State.
(2) The term `immovable property` as used in this Convention shall have the meaning which it has under the law of the Contracting State in which the property in question is situated.