THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNION OF SOVIET SOCIALIST REPUBLICS AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND

of July 31, 1985

About elimination of double taxation concerning taxes on the income and increase in value of property

The government of the Union of Soviet Socialist Republics and the Government of the United Kingdom of Great Britain and Northern Ireland, confirming the aspiration to develop and deepen economic, trade, industrial, cultural, scientific and technical cooperation, wishing to sign the Convention on elimination of double taxation concerning taxes on the income and increase in value of property, agreed about the following:

Article 1 Scope of the Convention

1. This Convention is applied to persons who for the purposes of the taxation are considered as having the permanent residence in one or in both Contracting States.

2. This Convention extends to the territory of each Contracting State and to those areas of the continental shelf adjacent to external border of the territorial sea of each State over which it performs according to international law the sovereign rights for the purpose of investigation and development of natural resources of these areas.

3. For the purposes of this Convention of the reference to any Contracting State are considered as the including references both to the territory of the relevant State, and to those areas of the continental shelf which adjoin to external border of the territorial sea of this State as it is determined in Item 2 of this Article.

Article 2 Taxes to which the Convention extends

1. This Convention extends to the following taxes:

a) in the Union of Soviet Socialist Republics:

(i) the income tax from foreign legal entities;

(ii) the income tax from the population;

b) in the United Kingdom of Great Britain and Northern Ireland:

(i) income tax;

(ii) tax on corporations;

(iii) tax on the income from property increase in value.

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