THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE ALGERIAN PEOPLE'S DEMOCRATIC REPUBLIC

of March 10, 2006

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

The government of the Russian Federation and the Government of the Algerian People's Democratic Republic, wishing 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 residents of one or both Contracting states.

Article 2 Taxes to which the Convention is applied

1. This Convention is applied to the taxes on the income and property levied for benefit of the Contracting state or its regional authorities, irrespective of method of their collection.

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

3. The operating taxes to which this Convention is applied, in particular, are:

a) in relation to Russia:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations;

(iv) property tax of physical persons

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

b) in relation to Algeria:

(i) tax on total income;

(ii) income tax of the companies;

(iii) tax on professional activity;

(iv) property tax;

(v) payments and tax on results of activities for investigation, search, development and transportation through pipelines of hydrocarbons and corresponding additional charges

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

4. This Convention is applied also to any identical or in essence to similar taxes which will be established after signature date of the Convention in amendment or instead of the existing taxes. Competent authorities of Contracting states notify each other on the essential changes made to their corresponding tax legislations.

Article 3 General determinations

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

a) the terms "Contracting State" and "other Contracting state" mean, depending on context, Russia or Algeria;

b) the term "Russia" means Russian Federation; in case of the use in geographical sense it means the territory of the Russian Federation, including internal waters and the territorial sea located over this territory airspace, and also exclusive economic zone and the continental shelf concerning which the Russian Federation performs the sovereign rights and the jurisdiction according to the federal legislation and international law;

c) the term "Algeria" means the Algerian People's Democratic Republic and in case of the use in geographical sense means the territory of the Algerian People's Democratic Republic, including the territorial sea, and beyond its limits - areas where according to international law and the national legal system the Algerian People's Democratic Republic performs the jurisdiction or the sovereign rights concerning investigation, developments, protection of natural resources of seabed, its subsoil and the covering waters and management of them;

d) the term "person" includes physical persons, the companies and any other associations of persons;

e) the term "national persons" means any physical persons having nationality of the Contracting state;

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

g) expressions "the company of one Contracting state" and "the company of other Contracting state" mean, respectively, the company operated by resident of one Contracting state and the company operated by resident of other Contracting state;

h) the term "international delivery" means any transportation sea or the aircraft operated by the company which actual place of management is in the Contracting state, except cases when sea or the aircraft is operated only between the Items located in other Contracting state;

i) expression means "competent authority":

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