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THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE KINGDOM OF DENMARK

of February 8, 1996

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

Government of the Russian Federation and Government of the Kingdom of Denmark,

wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and property,

agreed as follows:

Article 1 of Person to which the Convention is applied

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

Article 2 Taxes to which the Convention extends

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

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

3. Taxes to which this Convention is applied, in particular, are:

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 Denmark:

(i) the income tax paid to the State (indkomstskatten til staten);

(ii) municipal income tax (den kommunale indkosmstskat);

(iii) the income tax paid to acts (den amtskommunal indcomstskat);

(iv) specific income tax (den saerlige indkomstskat);

(v) church rate (kirkeskatten);

(vi) dividend tax (udbytteskatten);

(vii) tax on percent (renteskatten);

(viii) tax on the income from copyright and licenses (royaltyskatten);

(ix) the taxes levied according to the tax act of hydrocarbons (skatter i henhold til kulbrinteskatteloven);

(x) the property tax paid to the State (formueskatten til staten)

(further the referred to as "Danish taxes").

4. This Convention is applied also to any to similar or in essence to similar taxes which will be levied after the date of entry into force of the Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on essential changes in their relevant tax laws.

Article 3 General determinations

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

a) expressions mean "one Contracting State" and "other Contracting State", depending on context, the Russian Federation (Russia) or the Kingdom of Denmark (Denmark) and is included by their territories, and also areas where economic activity in relation to which according to international law the legislation of the relevant State is effective is performed. In relation to Denmark these expressions do not include the Faroe Islands and Greenland;

b) the term "person" includes physical person, the legal entity (including the company, the organization, to organization and the company) or any other consolidation of persons;

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

d) the term "company" means any form of the business activity performed by person with the permanent residence in the Contracting State;

e) expression "international delivery" means any transportation of passengers and loads by any vehicle performed by person with the permanent residence in one Contracting State out of limits of this Contracting State except cases when vehicles are operated only between the Items located in other Contracting State;

f) expression means "competent authority":

i) in Russia - the Ministry of Finance or the representative authorized by it;

ii) in Denmark - the Minister of the taxation or the representative authorized by it.

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

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