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

of November 26, 1996

About avoidance of double taxation and prevention of tax avoidance and violation of the tax legislation concerning taxes on the income and property

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

wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance and violation of the tax legislation 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 at all levels in the Contracting state irrespective of method of their collection.

2. All taxes levied from the total amount of the income, total cost of property or on 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 France:

(i) tax on the income;

(ii) tax on the companies;

(iii) the wage tax regulated by the Convention provisions applied depending on situation to profit of the companies or the income from independent personal services;

(iv) solidary tax on condition;

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

b) in relation to Russia - the taxes levied according to the following Laws of the Russian Federation:

(i) "About the income tax of the companies and organizations" (including tax on exceeding of the normalized salary size);

(ii) "About the income tax from physical persons";

(iii) "About the property tax of the companies";

(iv) "About the property tax of physical persons",

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

4. This Convention is applied also to any to similar 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 term "Contracting state" means, depending on context, Russia or France;

b) the term "France" means the European and overseas departments of the French Republic, including territorial waters, and beyond their limits - areas where according to international law the French Republic has the sovereign rights concerning investigation and development of natural resources of seabed, its subsoil and waters covering it;

c) the term "Russia" means the territory of the Russian Federation and includes its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law of 1982;

d) the term "public institution of the Contracting state" means concerning Russia - the public authorities created in Russia how they are determined in the Constitution of Russia, and concerning France the State, its territorial authorities, and also their legal entities of the public law;

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

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

g) the term "company of the State" means any form of business activity performed by resident of this State;

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

i) the term means "competent authority":

(i) in relation to France - the Minister who is responsible for the budget or its authorized representative;

(ii) in relation to Russia - the Ministry of Finance of the Russian Federation or his authorized representative, and also in case of application of provisions of Article 26 - the State Tax Administration of the Russian Federation or its authorized representative.

2. In case of application of the Convention at any time by the Contracting state any term or expression which in it are not determined make sense which is given them by the legislation of this State if other does not follow from context. The sense given to the term or expression by the tax legislation of this State concerning taxes to which the Convention extends prevails over sense which is given to this term or expression by other industries of the legislation of this State.

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