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of November 27, 1995

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

The government of the Russian Federation and the Government Is southern - the African Republic,

being guided by the aspiration to encourage and strengthen the relations between two States,

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 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 levied in the Contracting State irrespective of method of their collection.

2. All taxes levied from total of income or from separate elements of the income including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

3. The existing taxes to which this agreement extends, in particular, are:

a) in Russia - the taxes levied according to the following laws of the Russian Federation:

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

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

(further referred to as "the Russian tax");

b) in South Africa:

(i) normal tax;

(ii) tax on shareholders - nonresidents;

(iii) secondary tax on the companies

(further referred to as "tax of South Africa").

4. This agreement is applied also to any other, in essence to similar taxes which will be levied after signature date of the Agreement in amendment or instead of the taxes specified in Item 3.

5. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

a) the term "Russia" means the Russian Federation and when using in geographical sense means its territory, including internal waters and the territorial sea, airspace over them, and also exclusive economic zone and the continental shelf concerning which the Russian Federation performs the sovereign rights and jurisdiction according to the Federal Law and international law;

b) the term "South Africa" means Is southern - the African Republic and when using in geographical sense means its territory, including the territorial sea, and also any zone out of the territorial sea which were determined or can be determined according to the laws of South Africa and international law subsequently as the territories concerning which South Africa can perform the sovereign rights or jurisdiction;

c) expressions "one Contracting State" and "other Contracting State" mean, depending on context, Russia or South Africa;

d) the term "person" includes any physical person, the company, the company and any other consolidation of persons;

e) the term "company" means any corporate education or any other consolidation which for the tax purposes is considered as corporate education;

f) expressions "the company of one Contracting State" and "the company of other Contracting State" mean respectively the company managed by person with the permanent residence in one Contracting State and the company managed by person with the permanent residence in other Contracting State;

g) expression means "competent authority":

(i) in relation to Russia - the Ministry of Finance of the Russian Federation or the representative authorized by it;

(ii) in relation to South Africa - the Commissioner of the Internal revenue service or the representative authorized by him;

h) expression "international delivery" means any transportation sea or the aircraft operated by person with the permanent residence in the Contracting State except cases when sea or the aircraft is operated only between the Items located in the same Contracting State.

2. In case of application of this agreement by the Contracting State any term which is not determined in the Agreement has that significance which is attached to it by the legislation of this State concerning taxes to which this agreement extends if other does not follow from context.

Article 4. Person with the permanent residence

1. For the purposes of application of this agreement "person with the permanent residence in the Contracting State" means expression:

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