AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE SLOVAK REPUBLIC

of June 24, 1994

About avoidance of double taxation of the income and property

Government of the Russian Federation and Government of the Slovak Republic,

being guided by the aspiration to sign the Agreement on avoidance of double taxation of the income and property,

agreed as follows.

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are persons with the permanent residence or the permanent residence in one or in both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income and property levied in each of Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income on total cost of property or from their separate elements, including taxes on the income from alienation of personal and real estate belong to taxes on the income and property.

3. The operating taxes to which this agreement extends include:

a) in relation to the Russian Federation - the taxes levied according to the Laws of the Russian Federation:

i) "About the income tax of the companies and organizations";

ii) "About the income tax from physical persons";

iii) "About the property tax of the companies";

iv) "About the property taxes of physical persons" (further the referred to as "Russian taxes");

b) in relation to the Slovak Republic:

i) tax on the income of physical persons;

ii) tax on the income of legal entities;

iii) the real estate tax (further the referred to as "Slovak taxes")

4. The agreement will be applied also to any identical or in essence to similar taxes which will be levied after the introduction of the Agreement in force in addition to the existing taxes or instead of them. Competent authorities of Contracting States will notify each other on any essential changes which were made to their relevant tax laws.

Article 3. General determinations

1. In this agreement if other does not follow from context:

a) expressions "one Contracting State" and "other Contracting State" mean, depending on context, the Russian Federation - Russia and the Slovak Republic;

b) expression "the Russian Federation - Russia", used in geographical sense, means its territory, including internal waters and the territorial sea, airspace over them, and also the continental shelf and exclusive economic zone where the Russian Federation has sovereign rights and performs jurisdiction according to the procedure, determined by the Federal Law and rules of international law. The names "Russian Federation" and "Russia" are equivalent;

c) the expression "the Slovak Republic (Slovakia)" used in geographical sense means its territory over which the Slovak Republic performs the sovereignty or the rights and jurisdiction according to rules of international law and where the tax legislation of the Slovak Republic is applied. The names "Slovak Republic" and "Slovakia" are equivalent;

d) the term "person" means physical person, and also the legal entity and any consolidation of persons created by the legislation of Contracting States;

e) the term "company" means any formation or any consolidation of persons which for the purposes of the taxation is considered as corporate;

f) expression "the company of the Contracting State" means any form of implementation of business activity by person with the permanent residence in this State;

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