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)).
