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HMRC internal manual

Double Taxation Relief Manual

DT: Soviet Union: double taxation agreement, Article 13: Salaries and similar remuneration of individuals

(1) Salaries and other similar remuneration derived by a resident of a Contracting State in respect of an employment exercised or services rendered in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned or, in the case of technical specialists, not exceeding an aggregate of 365 days in two consecutive fiscal years;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment which the employer has in the other State.
(2) Notwithstanding the provisions of paragraph (1) of this Article, directors’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company or other legal person which is a resident of the other Contracting State may be taxed in that other State.
(3) Notwithstanding the preceding provisions of this Article, salaries and other similar remuneration derived by a resident of a Contracting State in respect of an employment exercised or services rendered in the other Contracting State shall not be taxable in that other State if the employment is exercised or the services are rendered directly:
(a) in connection with a building site, construction or assembly project in that other State which is within the provisions of sub-paragraph (a) of paragraph (2) of Article 5;
(b) for a permanent establishment in that other State of an air transport undertaking whose place of effective management is situated in the firstmentioned State;
(c) aboard a ship, aircraft, railway or road vehicle in international traffic provided the place of effective management of the person operating the ship aircraft, railway or road vehicle is situated in the first-mentioned State; or
(d) as a press, radio or television reporter or correspondent and the remuneration is derived from a source outside that other State.