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of February 11, 2007

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

Government of the Russian Federation and Government of the Kingdom of Saudi Arabia,

wishing to sign the Convention for the purpose of 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

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 the capital established on behalf of each of Contracting States, their political or administrative divisions or regional authorities irrespective of method of their collection.

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

3. This Convention extends to the following existing taxes:

a) in relation to Saudi Arabia:

i) Decline;

ii) the income tax, including the investment tax in natural gas

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

b) in relation to the Russian Federation:

i) income tax of the organizations;

ii) the income tax from physical persons;

iii) property tax of the organizations;

iv) property tax of physical persons

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

4. Provisions of this Convention are 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 both Contracting States will inform 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 terms "Contracting State" and "other Contracting State" mean the Russian Federation or the Kingdom of Saudi Arabia depending on context;

b) the term "Kingdom of Saudi Arabia" means the territory of the Kingdom of Saudi Arabia, and also includes the area outside territorial waters where the Kingdom of Saudi Arabia performs the sovereign rights and jurisdiction concerning the waters, seabed, subsoil and natural resources according to the legislation and international law;

c) the term "Russian Federation" means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf where the Russian Federation performs the sovereign rights and jurisdiction according to the Convention of the UN on maritime law of 1982;

d) the term "person" includes physical person, the company or any other consolidation of persons, including including political bodies (The state, its political or administrative division, or local authorities), partnership, trusts and funds;

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

f) the terms "company of the 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;

g) the term "national person" means:

i) any person having nationality or nationality of the Contracting State;

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

h) the term "international delivery" means any transportation sea or the aircraft operated by the company which actual place of management is located in the Contracting State, except cases when sea or the aircraft are operated only between Items in other Contracting State;

i) the term means "competent authority":

i) in relation to Saudi Arabia - the Ministry of Finance provided by the Minister of Finance or his authorized representative;

ii) in relation to the Russian Federation - the Ministry of Finance of the Russian Federation or his authorized representative.


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