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The convention between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela

of December 22, 2003

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

The government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela, wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation 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 established in each of Contracting States according to the legislation 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, taxes on the total amount of the salary paid by the companies 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 extends are, in particular:

a) in relation to Venezuela:

tax on the income and assets

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

b) in relation to the Russian Federation:

(i) income tax of the organizations;

(ii) the income tax from physical persons;

(iii) property tax of the organizations;

(iv) property tax of physical persons

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

4. This Convention is applied also to any identical or in essence to similar taxes which are levied after signature date of this Convention in amendment or instead of the existing taxes. At the end of every year competent authorities of Contracting States will notify each other on the corresponding changes made to 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 or the Bolivarian Republic of Venezuela depending on context;

b) the term "Venezuela" means the Bolivarian Republic of Venezuela;

c) the term "Russian Federation (Russia)" means the territory of the Russian Federation and includes its exclusive economic zone and the continental shelf;

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

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

f) the term "company of one Contracting State" and "company of other Contracting State" means 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 the Contracting State, except cases when sea or the aircraft are operated only between Items in other Contracting State;

h) the term means "competent authority":

(i) in relation to Venezuela - the Joint national service of tax and customs administration (Servicio Nacional Integrado de Administracion Aduanera y Tributaria - SENIAT), her authorized representative or the body determined as competent authority for the purposes of this Convention;

(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 person having nationality in case of Venezuela and nationality in case of Russia;

(ii) any legal entity, partnership and association which received such status based on the current legislation of the Contracting State.

2. In case of application of this Convention 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 concerning taxes to which this Convention is applied.

Article 4 Resident

1. For the purposes of this Convention the term "resident of the Contracting State" means:

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