DT16156 | Double Taxation Relief Manual: Russia: royalties

Royalties arising in the Russian Federation and paid to a resident of the United Kingdom who is the beneficial owner of the royalty are taxable only in the United Kingdom (Article 12(1)).

However, where the royalty is effectively connected (see INTM153110) with a permanent establishment or fixed base which the United Kingdom-resident recipient has in the Russian Federation it is not taxable under Article 12, instead the provisions of the business profits Article (Article 7) or the Independent personal services Article (Article 14) will apply (Article 12(3)).