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

of November 26, 1999

About avoidance of double taxation and prevention of tax avoidance on the income

The government of the Russian Federation and the Government of the Republic Iceland, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance 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 of income or from separate elements of the income including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

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

(a) in Iceland:

(i) domestic income tax;

(ii) emergency domestic income tax;

(iii) municipal income tax; and

(iv) tax on the income of bank institutions

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

(b) in the Russian Federation:

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

(ii) the income tax from physical persons

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

4. This Convention is applied also to any to similar or in essence to the similar taxes on the income 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. For the purposes of this Convention if other does not follow from context:

(a) the term "Iceland" means the Republic Iceland and when using in geographical sense means the Republic Iceland territory, including its territorial sea, and also any area adjacent to the territorial sea where Iceland according to rules of international law performs jurisdiction or the sovereign rights concerning seabed, its subsoil, including their natural resources, and also natural resources of adjacent waters;

(b) the term "Russia" means the Russian Federation and when using in geographical sense means the territory of the Russian Federation, including its territorial sea, and also any area adjacent to the territorial sea where Russia according to rules of international law performs jurisdiction or the sovereign rights concerning seabed, its subsoil, including their natural resources, and also natural resources of adjacent waters;

(c) the term "person" includes physical person, the company and any other consolidation of persons;

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

(e) 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;

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

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

(h) "competent authority" means the term:

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

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

(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 the status according to the current legislation of the Contracting State.

2. In case of application of this Convention at any time by the Contracting State any term which is not determined in it has that value, depending on context which is given it by the legislation of this State. In case of discrepancy between the tax laws of this State to which this Convention is applied and any other laws of this State the tax laws to which this Convention is applied will prevail.

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