THE CONVENTION BETWEEN THE RUSSIAN FEDERATION AND THE KINGDOM OF NORWAY

of March 26, 1996

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

The government of the Russian Federation and the Government of the Kingdom of Norway, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital, and also for the purpose of assistance to economic cooperation between two countries,

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 levied on behalf of the Contracting State or its regional 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 separate elements of the income or the capital including taxes on the income from alienation of personal or real estate are considered as taxes on the income and the capital.

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

- in the Russian Federation:

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

ii) the income tax from physical persons;

iii) property tax of the companies;

iv) property tax of physical persons

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

- in the Kingdom of Norway:

i) domestic income tax (inntektsskatt til staten);

ii) district municipal income tax (inntektsskatt til fylkeskommunen);

iii) municipal income tax (inntektsskatt til kommunen);

iv) national fees in Fund of distribution of taxes (fellesskatt til Skattefordelingsfondet);

v) domestic tax on the capital (formuesskatt til staten);

vi) the municipal tax on the capital (formuesskatt til kommunen);

vii) domestic tax concerning the income and the capital received in connection with investigation and development of underwater oil resources and activities and the related works including transportation of the made oil through the pipeline (skatt til staten vedrorende inn tekt og formue i forbindelse med undersokelse etter og utnyttelse av undersjoiske petroleumsforekomster og dertil knyttet virksomhet og arbeid, herunder rorledningstransport av utvunnet petroleum); and

viii) national charges from the remunerations paid to nonresident actors (avgift til staten av honorarer som tilfaller kunstnere bosatt i utlandet)

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

4. This Convention is applied also to any to similar or in essence to the similar taxes imposed by each Contracting State after signature date of this Convention in amendment or instead of the existing taxes.

Article 3 General determinations

1. For the purposes of this Convention if other does not follow from context:

a)

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

- the term "Norway" means the Kingdom of Norway, including any zone outside territorial waters of the Kingdom of Norway where the Kingdom of Norway according to the Norwegian legislation and according to rules of international law can perform the rights concerning seabed, sea subsoil and natural resources; this term does not include Svalbard, Jan Mayen and the territories dependent on Norway ("biland");

b) the term "national person" means:

i) all physical persons having nationality of the Contracting State;

ii) all legal entities, partnerships and associations which received such status according to the current legislation of the Contracting State;

c) the term "tax" means any tax considered in article 2 of this Convention;

d) the term "person" includes 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) the terms "Contracting State" and "other Contracting State" mean Russia or Norway, depending on context;

g) 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;

h) 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 other Contracting State;

i) the term means "competent authority":

- in Russia - the Ministry of Finance or its authorized representative;

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