Agreement between the Government of the Russian Federation and Government of the Republic of Uzbekistan on avoidance of double taxation of the income and property

of March 2, 1994

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

wishing to sign the Agreement on avoidance of double taxation of the income and property,

agreed as follows:

Article 1. Scope

1. 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 extends to the taxes on the income (profit) and on property levied on behalf of each Contracting State irrespective of method of their collection.

2. All taxes levied from total income or on part of the income, including taxes on the income from alienation of personal or real estate, and also the property increment value duties belong to taxes on the income (profit) and on property.

3. Taxes to which this agreement extends are:

- in the Russian Federation - the taxes levied according to the following laws:

(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 tax of physical persons" (further referred to as as "The Russian taxes");

- in the Republic of Uzbekistan:

(i) tax on the income of the companies, associations and organizations;

(ii) the income tax from citizens of Uzbekistan, foreign citizens and stateless persons;

(iii) property tax of the companies;

(iv) the property tax of physical persons (further referred to as as "taxes of Uzbekistan").

4. This Agreement will be is applied also to any to similar or in essence to similar taxes which will be levied by any of Contracting States after signature date of this agreement in amendment or instead of the taxes specified in Item 3 of this Article. Competent authorities of Contracting States will notify each other on any essential changes in their tax legislations.

Article 3. General determinations

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

a)

- the term "Russian Federation (Russia)" means the Russian Federation and when using in geographical sense includes the territories of her subjects, internal waters and the territorial sea, airspace over them, and also economic zone and the continental shelf where the Russian Federation can perform the sovereign rights and jurisdiction according to rules of international law and where the tax legislation of the Russian Federation is effective,

- the term "Uzbekistan" means the Republic of Uzbekistan and when using in geographical sense includes its territory, internal waters, airspace over them where the Republic of Uzbekistan can perform the sovereign rights and jurisdiction, including the rights on use of subsoil and natural resources, according to rules of international law and where the legislation of the Republic of Uzbekistan is effective;

b) the terms "Contracting State" and "other Contracting State" mean Russia or Uzbekistan depending on context;

c) the term "person" includes the physical person, any legal entity and any other consolidation of persons created according to the laws of the Contracting State and which is considered for the purposes of the taxation as the legal entity;

d) the term "company" means any corporate consolidation or any organization which for the purposes of the taxation is considered as corporate consolidation;

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