The convention between the Government of the Russian Federation and the Government of the Lebanese Republic

of April 8, 1997

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

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

wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and aiming to encourage economic cooperation between two states,

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 on behalf of the Contracting State, its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal and real estate are considered as taxes on the income.

3. Taxes to which this Convention is applied, in particular, are:

a) in relation to the Lebanese Republic:

(i) income tax of industrial, commercial and non-commercial professions;

(ii) wage tax, salary and pensions;

(iii) tax on the income from the movable capital; and

(iv) tax on structures (tax on income gained from use of structures)

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

b) in relation to the Russian Federation:

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

(ii) the income tax from physical persons

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

4. This Convention is applied also to similar or in essence to the similar taxes levied after signature date of this Convention in amendment or instead of the existing taxes mentioned in Item 3. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws during the reasonable period of time after such changes.

Article 3 General determinations

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

a) the terms "one Contracting State" and "other Contracting State" mean the Lebanese Republic or the Russian Federation depending on context;

b) the term "Lebanese Republic" 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;

c) the term "Russian Federation" 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;

d) the term "political division" is applied only in case of the Russian Federation and means her subjects or any other is administrative - territorial educations;

e) the term "tax" means the Lebanese tax or the Russian tax depending on context;

f) the term "person" includes any physical person, the company or any other consolidation of persons;

g) the term "company" means any corporate consolidation or any other education which is considered as corporate education for the purposes of the taxation;

h) the terms "company of one Contracting State" and "company of other Contracting State" mean the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

i) the term "national person" means:

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association which received such status according to the current legislation of the Contracting State;

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

k) the term means "competent authority":

(i) in relation to the Lebanese Republic - the Minister of Finance or his authorized representative;

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