The Double Taxation Relief (Taxes on Income) (Russian Federation) Order 1994

Article 22 Elimination of double taxation

(1) Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom (which shall not affect the general principle hereof):

(a) Russian Federation tax payable under the laws of the Russian Federation and in accordance with this Convention, whether directly or by deduction, on profits, income or capital gains from sources within the Russian Federation (excluding in the case of a dividend, tax payable in the Russian Federation in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or gains by reference to which the Russian Federation tax is computed;

(b) in the case of a dividend paid by a company which is a resident of the Russian Federation to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit shall take into account (in addition to any Russian Federation tax for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the Russian Federation tax payable by the company in respect of the profits out of which such dividend is paid.

(2) Where a resident of the Russian Federation derives income from the United Kingdom, which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, the amount of tax on that income payable in the United Kingdom, shall be credited against the tax levied in the Russian Federation imposed on that resident. The amount of credit, however, shall not exceed the amount of the tax of the Russian Federation on that income computed in accordance with its taxation laws and regulations.

(3) For the purposes of paragraphs (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other Contracting State.