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of October 12, 1995

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

The government of the Russian Federation and the Allied Government of the Federal Republic of Yugoslavia, 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 extends

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

2. All taxes levied from total of income, the 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, 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. Taxes to which the Convention is applied are:

- in the Russian Federation:

1) income tax (income) of the companies and organizations;

2) the income tax from physical persons;

3) property tax of the companies;

4) the property taxes of physical persons (further the referred to as "Russian taxes");

- in Yugoslavia:

1) corporate profit tax;

2) the income tax from citizens;

3) property tax;

4) tax on the income from the international transport activities (further the referred to as "Yugoslavian 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 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:

1) the terms "Contracting State" and "other Contracting State" mean Russia or Yugoslavia depending on context;

2) the term "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 Russia has sovereign rights and performs jurisdiction according to the federal legislation and rules of international law;

3) the term "Federal Republic Yugoslavia (Yugoslavia)" when using in geographical sense means the overland territory of Yugoslavia, its internal sea waters and strip of the territorial sea, airspace over them, and also seabed and sea subsoil of part of the high sea behind external border of the territorial sea over which Yugoslavia performs the sovereign rights with research purpose and operation of natural resources according to its domestic legislation and rules of international law;

The term "policy-administrative divisions" means 4):

(i) in relation to Russia - subjects of the Russian Federation according to its Constitution;

(ii) in relation to Yugoslavia - the republics;

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

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

7) 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;

8) expression "international delivery" means any transportation sea, river or the aircraft operated by resident of the Contracting State except cases when it is transported only between Items in other Contracting State;

The term "competent authority" means 9):

(i) in relation to Russia - the Ministry of Finance of the Russian Federation or his authorized representative;


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