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

of November 17, 1995

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

(Protocol as amended of 27.04.2007)

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

agreed as follows:

Article 1 of Person to which the Convention is applied

The present the Convention is applied to persons who are residents of one or both Contracting States.

Article 2 Taxes to which the Convention extends

1. This Convention is applied to the taxes on the income and the capital levied on behalf of the Contracting State or its political divisions or regional authorities irrespective of method of their collection.

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

3. The existing taxes to which this Convention is applied are:

a) in the Czech Republic:

(i) the income tax from physical persons;

(ii) tax on the income of legal entities;

(iii) non-personal tax

(further referred to as "the Czech tax");

b) in the Russian Federation:

(i) the income tax from physical persons;

(ii) income tax of the companies and organizations;

(iii) property tax of physical persons;

(iv) property tax of the companies and organizations

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

4. This Convention is applied also to any to similar or in essence to the similar taxes levied after signature date of the 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) expression "the Czech Republic" means the territory of the Czech Republic where the Czech Republic can perform the sovereign rights according to the Czech legislation and rules of international law;

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

c) expressions "Contracting state" and "other Contracting State" mean Russia or the Czech Republic 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 education which for the tax purposes is considered as corporate consolidation;

f) expressions "the company of one Contracting State" and "the 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;

g) expression means "national person":

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association which received such status on the basis of the laws existing in the Contracting State;

h) the term "international delivery" means any transportation sea, river or the aircraft operated by resident of the Contracting state, except as specified, when sea, river or the aircraft are operated between Items in other Contracting state;

i) expression means "competent authority":

(i) in the Czech Republic - the Minister of Finance or his authorized representative;

(ii) in case of the Russian Federation - the Ministry of Finance or its authorized representative.

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