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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 18: Pensions

(1) Pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State shall be taxable only in that State.
(2) Notwithstanding the provisions of paragraph (1) of this Article any pension paid by or out of funds created by a Contracting State or an administrative political subdivision including any local authority thereof to an individual in respect of past employment or services rendered to that State or authority shall be taxable only in that State. However such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.