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The convention between the Government of the Russian Federation and the Government of the Federal Republic of Brazil

of November 22, 2004

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

The government of the Russian Federation and the Government of the Federal Republic of Brazil, wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

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 extends

1. Taxes to which this Convention is applied are:

a) in relation to Russia:

(i) income tax of the organizations;

(ii) the income tax from physical persons

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

b) in relation to Brazil:

the federal tax on the income

(further the referred to as "Brazilian tax").

2. This Convention is applied also to any identical or in essence to similar taxes on the income which are established by any Contracting State after signature date of this Convention in amendment or instead of above-mentioned taxes. Competent authorities of Contracting States will notify each other on any essential changes made to their relevant tax laws.

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 the Russian Federation or the Federal Republic Brazil depending on context;

b) the term "Russian Federation (Russia)" means the territory of the Russian Federation, including its continental shelf and exclusive economic zone where the Russian Federation performs the sovereign rights and jurisdiction according to international law;

c) the term "Federative Republic of Brazil (Brazil)" means the territory of the Federal Republic of Brazil, including its territorial sea determined according to the Convention of the UN on maritime law and the corresponding seabed and subsoil, and also any sea space outside the territorial sea, including seabed and subsoil concerning which according to international law Brazil performs the sovereign rights on investigation and operation of natural resources;

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

e) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

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

g) 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 such transportation is performed only between Items in other Contracting State;

h) the term "national person" means:

(i) any physical person having:

- in relation to Russia the Russian citizenship; and

- in relation to Brazil the Brazilian nationality;

(ii) any legal entity, partnership and association who received such status based on the current legislation of the Contracting State;

i) 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 Federal Republic of Brazil - the Minister of Finance, the Secretary of the federal income or their authorized representatives.

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

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