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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Soviet Union: double taxation agreement, Article 12: Capital gains

(1) Gains derived by a resident of a Contracting State from the alienation of immovable property as defined in paragraph (2) of Article 11 and situated in the other Contracting State may be taxed in that other State.
(2) Gains from the alienation of movable property forming part of the property of a permanent establishment which a resident of a Contracting State has in the other Contracting State may be taxed in that other State.
(3) Notwithstanding the provisions of paragraph (2) of this Article, gains from the alienation of ships, aircraft, railway and road vehicles operated in international traffic and movable property pertaining to the operation of such ships, aircraft, railway and road vehicles shall be taxable only in the Contracting State in which, under the provisions of Article 7, profits from such activities are taxable.
(4) Gains from the alienation of any property other than that referred to in paragraphs (1), (2) and (3) of this Article shall be taxable only in the Contracting State of which the alienator is a resident.