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The agreement between the Government of the Russian Federation and the Government of Georgia on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and property

of August 4, 1999

The government of the Russian Federation and the Government of Georgia, being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both Contracting States, and for the purpose of avoidance of double taxation of the income and property decided to sign this agreement and agreed as follows:

Article 1 of Person to which the Agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States.

Article 2 Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income (profit) and property levied in Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income or the capital or on separate elements of the income or property, including the taxes on the income from alienation of personal or real estate levied from the total amount of the salary or salary paid by the companies and also taxes on property value addition are considered as taxes on the income (profit) and property.

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

a) in Georgia:

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

(ii) the income tax from physical persons;

(iii) property tax of the companies;

(IV) the property tax from physical persons (the hereinafter referred to as "taxes of Georgia")

b) in 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; and

(IV) the property tax of physical persons (further the referred to as "taxes of the Russian Federation");

4. This agreement is applied also to any identical or in essence to similar taxes which will be levied in any of Contracting States in addition to the existing taxes or instead of them, after signature date of this agreement. Competent authorities of Contracting States will notify each other on any essential changes in their corresponding tax legislation.

Article 3 General determinations

1. For the purpose of this agreement if other does not follow from context:

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

b) the term "Georgia" means all overland space in its borders recognized as the world community, internal waters and the territorial sea, their subsoil and airspace over them to which sovereignty of Georgia, and also exclusive economic zone and the continental shelf, adjacent to its territorial sea, concerning which Georgia performs the sovereign rights according to international law extends;

c) the term "Russian Federation" means the territory of the Russian Federation, and also 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" means physical person, the company or any other consolidation of persons;

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

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, the aircraft, automobile or the rail vehicle operated by the company of the Contracting State except cases when such transportation is performed only between the Items located in other Contracting State;


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