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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 17 Income from Government service

(1) Notwithstanding the provisions of Article 13 remuneration paid by a Contracting State or an administrative political subdivision including any local authority thereof to an individual in respect of employment or services rendered to that State or subdivision or authority shall be taxable only in that State.
(2) Notwithstanding the provisions of paragraph (1) of this Article such remuneration shall be taxable only in the other Contracting State if the employment or services are rendered in that State and the individual is a resident of that State who:

(a) is a national of that State; or
(b) did not become a resident of that State solely for the purpose of rendering the employment or services.
(3) Where an individual mentioned in paragraph (1) of this Article derives remuneration from commercial activities the provisions of Article 13 shall apply.