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

of April 9, 1996

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

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

wishing to sign the Convention for avoidance of double taxation concerning taxes on the income and the capital and for prevention of evasion from the taxation, and also for the purpose of encouragement of 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 each Contracting State or its political or administrative division or regional authority 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, and also taxes on the income from increase in capital value are considered as taxes on the income and the capital.

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

(a) in relation to the Russian Federation:

1 - income tax (income) of the companies and organizations;

2 - the income tax from physical persons;

3 - property tax of the companies;

4 - property tax of physical persons

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

(b) in relation to Italy:

1 - individual income tax (l "imposta sul reddito delle persone fisiche);

2 - corporate income tax (l "mposta sul reddito delle persone giuridiche);

3 - regional tax on productive activity ("l" imposta regionale sulle attivita produttive"), (in the Protocol edition of 13:06. 2009) irrespective of, they keep at source or not,

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

4. This Convention is applied also to any to similar or in essence to the similar taxes 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 any essential changes in their relevant tax laws.

Article 3 General determinations

1. In this Convention if other does not follow from context:

(a) the term "Russia" means the Russian Federation and 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 where the Russian Federation performs the sovereign rights and jurisdiction according to rules of international law and the federal legislation;

(b) the term "Italy" means the Republic of Italy and when using in geographical sense means its territory, including internal waters, the territorial sea and airspace over them, and includes any area outside territorial waters of Italy which according to rules of international law and the legislation of Italy concerning investigation and development of natural resources can be determined as the area where Italy can perform the rights concerning seabed, sea subsoil and natural resources;

(c) the terms "Contracting State" and "other Contracting State" mean Russia or Italy, depending on context;

(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 purposes of the taxation is considered as corporate consolidation;

(f) 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;

(g) 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 such sea or the aircraft is operated only between Items in other Contracting State;

(h) the term "national person" means:

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