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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE UNITED ARAB EMIRATES

of December 7, 2011

About income assessment from investments of contracting states and their financial and investment institutions

Government of the Russian Federation and Government of the United Arab Emirates,

wishing to develop and strengthen economic and financial cooperation between them, and also cooperation in the field of investments,

recognizing that provision of mutual tax benefits to the public financial and investment institutions will promote further development of the existing strategic partnership and increase in capital movement between two countries,

agreed as follows:

Article 1

1. Taxes to which this agreement extends, in particular, are:

a) in the Russian Federation:

income tax of the organizations;

b) in the United Arab Emirates:

(i) tax on corporations,

(ii) the income tax, including provincial taxes on the income levied in each of the Emirates.

2. This agreement is also applied to any identical or in essence to similar taxes which are established by any of Contracting states after signature date of this agreement in amendment or instead of the taxes mentioned in Item 1 of this Article. Competent authorities of Contracting states will notify each other on any essential changes made to their relevant tax laws.

3. Irrespective of any other provisions of this agreement no provision of this agreement affects the right of any political division or local government of the United Arab Emirates to apply the own laws and regulations concerning the taxation of the income and the capitals relating to ownership, management, production, investigation, operation, transportation and distribution of natural resources and hydrocarbons including oil and gas, and also their condensates, derivative and primary by-products. In case of discrepancy between this Item and any other provision of this agreement this Item will prevail.

Article 2

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

a) the terms "Contracting State" and "other Contracting state" mean the Russian Federation or the United Arab Emirates depending on context;

b) the term "Russian Federation" means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf determined according to the Convention of the United Nations on maritime law (1982);

c) the term "United Arab Emirates" means the territory of the United Arab Emirates which is under their jurisdiction and also any area outside the territorial sea, air and underwater space in which the United Arab Emirates perform the sovereign rights and jurisdiction concerning any activities performed in their waters on seabed and in subsoil concerning investigation and development of natural resources according to their legislation and international law;

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

e) the term "resident of the Contracting state" for the purposes of this agreement means any person, other than physical which according to the legislation of this Contracting state is subject in it to the taxation based on its place of registration, the place of management or any other criterion of similar nature, and also includes this Contracting state and its any political division or local government body. If according to the previous provisions of this subitem such person is resident of both Contracting states, it will be considered as resident only of that Contracting state in which there is its actual place of management;

f) the term "political divisions" in relation to the Russian Federation means subjects of the Russian Federation which are determined as those in accordance with the legislation of the Russian Federation;

g) the term "local government of the United Arab Emirates" means the government of any Emirate which is part of the United Arab Emirates (Abu Dhabi, Dubai, Sharjah, Ras-el-Haymy, El-Fudzhayra, Umm-el-Kayvayna and Adzhman);

h) the term means "competent authority":

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

(ii) in relation to the United Arab Emirates - the Ministry of Finance of the United Arab Emirates or his authorized representative;

i) expression "The contracting state or its financial and investment institutions" means:

(i) in the Russian Federation:

- Government of the Russian Federation;

- government of any subject of the Russian Federation;

- Central Bank of the Russian Federation;

- any financial or investment organization, organization, the agency, body or other education which are completely belonging to the Russian Federation, the Government of the Russian Federation or the government of any subject of the Russian Federation;

- Pension Fund of the Russian Federation;

(ii) in the United Arab Emirates:

- Government of the United Arab Emirates;

- any local government of the United Arab Emirates (Abu Dhabi, Dubai, Sharjah, Ras-el-Haymy, El-Fudzhayra, Umm-el-Kayvayna and Adzhman);

- Central Bank of the United Arab Emirates;

- Investment management of Abu Dhabi;

- Emirates investment management;

- any financial or investment organization, organization, the agency, body or other education which are completely belonging to the Government of the United Arab Emirates or any local government of the United Arab Emirates;

- public pension fund of the United Arab Emirates.

Competent authorities of Contracting states can periodically approve distribution of the privileges provided by this agreement for any other similar education which is completely belonging to the Contracting state including its federal government or any government of the subject of the Russian Federation, or any local government of the United Arab Emirates.

This agreement does not affect the right of one Contracting state to receive benefit from tax incentives, releases and privileges which are provided or can be provided by other Contracting state according to its laws and regulations.

2. In case of application of this agreement by the Contracting state any term which is not determined in it has that value if other which is given it by the legislation of this state concerning taxes to which this agreement is applied does not follow from context, and interpretation which is given to the term by the tax legislation of this state prevails over the interpretation given by other laws of this state.

Article 3

1. Income gained by the Contracting state or its financial and investment institutions from the real estate (including the income from rural or forestry) which is in other Contracting state can be assessed with tax in this other state.

2. The term "real estate" has that value which it has by the legislation of that Contracting state in which there is considered property.

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