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The Double Taxation Relief (Taxes on Income) (Russian Federation) Order 1994
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- 1994 No. 3213
- SCHEDULE
- Article 23
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Article 23Limitation of relief
(1) Where under any provision of this Convention any income is relieved from tax in the Russian Federation and, under the law in force in the United Kingdom a person, in respect of that income, is subject to tax by reference to the amount thereof which is remitted to or received in the United Kingdom and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the Russian Federation shall apply only to so much of the income as is taxed in the United Kingdom.
(2) Notwithstanding the provisions of any other Article of this Convention, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that Contracting State, on income or capital gains shall not receive the benefit of any reduction in or exemption from tax provided for in this Convention.
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