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

of October 2, 1995

About avoidance of double taxation concerning taxes on the income and property

The government of the Russian Federation and the Government of the Republic of Croatia, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and property,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are residents of one or both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to taxes on the income and property, the collectable Contracting State, its political division or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income, the total amount of property or from separate elements of the income or property including the increment value duties of property and on the income from alienation of personal or real estate are considered as taxes on the income and property.

3. The operating taxes to which this agreement is applied:

a) in the Russian Federation:

i) income taxes (income) of the companies and organizations,

ii) the income tax from physical persons,

iii) property tax of the companies and

iv) property tax of physical persons

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

b) in the Republic of Croatia:

(i) income tax,

(ii) tax on the income

(further referred to as "the Croatian tax").

4. This agreement is applied also to any to similar or in essence to the similar taxes levied after signature date of the Agreement in amendment or instead of the operating taxes. 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) expression Russian Federation when using in geographical sense means its territory, including internal waters and the territorial sea, airspace over them, and also economic zone and the continental shelf where the Russian Federation performs the sovereign rights and jurisdiction according to its domestic legislation and rules of international law;

b) the term "Croatia" when using in geographical sense means the territory of the Republic of Croatia within its internationally acknowledged borders, and also any zone outside territorial waters of the Republic of Croatia over which the Republic of Croatia according to rules of international law and the legislation of the Republic of Croatia performs the sovereign rights and jurisdiction;

c) expressions "Contracting state" and "other Contracting State" mean the Russian Federation or the Republic of Croatia, depending on context;

d) the term "tax" means the Russian or Croatian tax, depending on context;

e) the term "person" includes any physical person, the company or any consolidation of persons;

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

g) expressions "the company of one Contracting State" and "the company of other Contracting State" mean respectively the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

h) expression "international delivery" means any transportation sea, river, the aircraft or road transportation operated by the company which is resident of one Contracting State, except cases when sea, river, the aircraft or road transportation is operated only between Items in other Contracting State;

i) the term "national person" means any physical person having nationality of the Contracting State and any legal entity, partnership or association which received such status on the basis of the legislation existing in the Contracting State;

j) expression means "competent authority":

i) in case of the Russian Federation - the Ministry of Finance of the Russian Federation or his authorized representative;

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