Interest arising in the Russian Federation and paid to a
resident of the United Kingdom who is the beneficial owner of the
interest is taxable only in the United Kingdom (Article 11(1)),
except where the interest is effectively connected (see INTM153110)
with a permanent establishment or fixed base which the United
Kingdom resident recipient has in the Russian Federation.
In the latter circumstances the provisions of the Business
Profits Article (Article7) or the Independent Personal Services
Article (Article 14) will apply.
