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Operations of articles 5 - 22 and 24 are suspended by the Russian Federation according to the Presidential decree the Russian Federation of August 8, 2023 No. 585


of June 26, 2000

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 Hellenic Republic, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance 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 levied on behalf of the Contracting State or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income, total cost 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 capital gain 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 Hellenic Republic:

i) income tax and property tax of physical persons;

ii) income tax and property tax of legal entities

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

b) in relation to 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").

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. 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 (Russia) or the Hellenic Republic, depending on context;

b) the term "Hellenic Republic" means the territory of the Hellenic Republic and part of the sea which is outside the territorial sea and adjacent to it, the seabed and its subsoil which are near the Mediterranean Sea where the Hellenic Republic performs the sovereign rights for the purpose of investigation, production or operation of natural resources in these areas according to international law;

c) the term "Russian Federation" means the territory of the Russian Federation and includes its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law of 1982;

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 "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 "national person" means:

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

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

h) the term "international delivery" means any transportation sea or the aircraft, except cases when such sea or the aircraft is operated only between Items in one Contracting State;


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