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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 21: Non-discrimination

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation which is other or more burdensome than the taxation to which nationals of that other State in the same circumstances are or may be subjected.
(2) The taxation of the income or profits which a resident of a Contracting State derives through a permanent establishment in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on the income or profits derived through a permanent establishment in that State by residents of third States carrying on similar activities in the same circumstances.
(3) Nothing contained in this Article shall be construed as obliging either Contracting State to grant to individuals not resident in that State any of the allowances, reliefs and reductions for tax purposes, which are granted to individuals who are resident in that State.