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

Article 28 Entry into force

(1) Each of the Contracting States shall notify to the other in writing through the diplomatic channel the completion of the internal procedures required by the law applied in that Contracting State for the bringing into force of this Convention.This Convention shall enter into force on the date of the later of these notifications and shall thereupon have effect:

(a) in the United Kingdom:

(i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April in the calendar year next following that in which the Convention enters into force;

(ii) in respect of corporation tax, for any financial year beginning on or after 1st April in the calendar year next following that in which the Convention enters into force;

(b) in the Russian Federation:

(i) in respect of taxes withheld at source for amounts paid or credited starting from the first of January of the calendar year, following the year in which the Convention enters into force;

(ii) in respect of other income taxes for taxable periods beginning on or after the first of January of the calendar year, following the year in which the Convention enters into force.

(2) Subject to the provisions of paragraph (3) of this Article as regards relations between the United Kingdom and the Russian Federation, the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation of Air Transport Undertakings and their Employees signed at London on 3rd May 1974 (hereinafter referred to as “the 1974 Agreement”) and the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation with respect to Taxes on Income and Capital Gains signed at London on 31st July 1985 (hereinafter referred to as “the 1985 Convention”) shall cease to have effect in respect of the taxes to which this Convention applies in accordance with the provisions of paragraph (1) of this Article.

(3) Where any provision of the 1985 Convention would have afforded any greater relief from tax than is due under this Convention, any such provision as aforesaid shall continue to have effect:

(a) in the United Kingdom, for any year of assessment, financial year or chargeable period, and

(b) in the Russian Federation, for any taxable period,

beginning, in either case, before the entry into force of this Convention.