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The convention between the Government of the Russian Federation and the Government of the Kingdom of Thailand

of September 23, 1999

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 Kingdom of Thailand, 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. This Convention is applied to the taxes on the income levied in the Contracting State irrespective of method of their collection.

2. All taxes levied from total income or from separate elements of the income 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 capital gain taxes are considered as taxes on the income.

3. The existing taxes to which the Convention extends, in particular, are:

a) in relation to Russia - taxes on the income and the profit levied according to the following Laws:

- "About the income tax of the companies and organizations"; and

- "About the income tax from physical persons"

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

b) in relation to Thailand:

- income tax;

- oil income tax

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

4. The convention is applied also to any identical or in essence to similar taxes which are levied after signature date of this Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on the considerable 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 term "Russia" means the territory of the Russian Federation, including any sea zone adjacent to the territorial sea over which the Russian Federation performs the sovereign rights and jurisdiction according to the national legal system and rules of international law;

b) the term "Thailand" means the territory of the Kingdom of Thailand, including any sea zone adjacent to the territorial sea over which the Kingdom of Thailand performs the sovereign rights and jurisdiction according to the national legal system and rules of international law;

c) the term "Contracting State" and "other Contracting State" mean Russia or Thailand depending on context;

d) the term "person" includes physical person, the company and any other consolidation of persons, and also any education considered as taxable unit according to the existing tax legislation of each Contracting State;

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

f) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively the business activity performed by resident of one Contracting State and the business activity performed by resident of other Contracting State;

g) the term "tax" means the Thai tax or the Russian tax depending on context;

h) the term "citizen" means any physical person having nationality of the Contracting State;

i) the term "international delivery" means any transportation sea or the aircraft operated by the company of the Contracting State except cases when sea or the aircraft is operated only between Items in the Contracting State; and

j) the term "competent authority" means in relation to Russia the Ministry of Finance of the Russian Federation or his authorized representative and in relation to Thailand the Minister of Finance or his authorized representative.

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