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THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE REPUBLIC OF ALBANIA

of April 11, 1995

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

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

being guided by the aspiration to sign the Convention on avoidance of double 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 extends to taxes on the income and the property taxes applied by the Contracting State or regional authorities irrespective of method of their collection.

2. As taxes on the income and property all taxes levied from total of income or property or from separate elements of the income or property including taxes on the income from alienation of personal and real estate, and also the property increment value duties will be considered.

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

a) in the Russian Federation:

(i) taxes on the income and profit levied according to the Laws of the Russian Federation "About the income tax of the companies and organizations" and "About the income tax from physical persons";

(ii) the property taxes levied according to the Laws of the Russian Federation "About the property tax of the companies", "About the property taxes of physical persons"

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

b) in Albania:

(i) income tax;

(ii) taxes on small business;

(iii) tax on personal incomes;

(iv) property taxes;

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

4. The convention is applied also to any to similar or in essence to similar taxes which will be levied after signature date of this Convention in amendment or instead of the existing 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 Convention if other does not follow from context:

a) the term "Russian Federation" when using in geographical sense means its territory, including internal waters and the territorial sea, airspace over them, and also the continental shelf and exclusive economic zone where the Russian Federation has sovereign rights and performs jurisdiction according to the Federal Law and rules of international law. The names "Russian Federation" and "Russia" are equivalent;

b) the term "Albania" means the Republic Albania and when using in geographical sense means the territory of the Republic of Albania, including territorial waters and airspace over them, and also any zone outside territorial waters of the Republic of Albania which according to international law and the laws of the Republic of Albania is the territory within which the Republic Albania can perform the rights concerning use of seabed and subsoil and their natural resources;

c) the terms "Contracting State" and "other Contracting State" mean the Russian Federation or Albania depending on context;

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

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

f) the terms "company of the Contracting State" and "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) the term "national person" means:

(i) in relation to the Russian Federation:

any physical person having citizenship of the Russian Federation;

(ii) in relation to Albania:

- any physical person having citizenship of Albania;

- any legal entity, partnership or association which received that status based on the current legislation of Albania;

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