AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE REPUBLIC OF ARMENIA

of December 28, 1996

About elimination of double taxation on the income and property

The government of the Russian Federation and the Government of the Republic of Armenia, being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both States and for the purpose of elimination of double taxation concerning taxes on the income and property, prevention of tax avoidance and non-admission of tax discrimination, 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 extends to taxes on the income and property levied in the Contracting State irrespective of method of their collection.

2. All taxes levied from the total amount of the income on total cost of property, or from their separate elements are considered as taxes on the income and on property.

3. The existing taxes to which this agreement extends are, in particular:

a) in relation to Russia:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations;

(iv) property tax of physical persons;

b) in relation to Armenia:

(i) income tax of legal entities;

(ii) the income tax from physical persons;

(iii) property tax.

4. This agreement is applied also to any identical or in essence to the similar taxes mentioned in Item 1 of this Article which will be levied in amendment or instead of the existing taxes after signature date of this agreement.

Competent authorities of Contracting States will timely notify each other on the essential changes made to the relevant tax laws and other regulations connected with the tax legislation.

Article 3 General determinations

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

a) expressions "one Contracting State" and "other Contracting State" mean, depending on context, Russia or Armenia;

b) the term "Russia" means the Russian Federation and when using in geographical sense means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf;

c) the term "Armenia" means the Republic of Armenia and when using in geographical sense means the territory of the Republic of Armenia;

d) the term "person" includes the physical person, the company and any consolidation of persons considered as the subject of the taxation;

e) expression "the company of the Contracting State" means the company registered according to the legislation of this State;

f) expression "international delivery" means any transportation sea or the aircraft, automobile or by rail, performed by resident of the Contracting State, except as specified when such transportation is performed only between the Items located in other Contracting State;

g) expression means "competent authority":

in relation to Russia - the Ministry of Finance of the Russian Federation or the representative authorized by it;

in relation to Armenia - the Ministry of Finance of the Republic of Armenia and Committee of state revenues under the Government of the Republic of Armenia or their authorized representatives.

2. In case of application of this agreement by the Contracting State any term or expression which is not determined in the Agreement will have that significance which is attached to it by the legislation of this State if other does not follow from context. In case of discrepancy between the legislation of the Contracting State concerning taxes to which the Agreement extends and other areas of the legislation of this State apply the legislation to taxes to which the Agreement extends.

Article 4 Resident

1. In case of application of this agreement expression "the resident of the Contracting State" means authority of this State, and also any person who by the legislation of this State is subject to the taxation in it based on residence, place of registration or other similar criterion.

2. In case according to provisions of Item 1 of this Article, the physical person is resident of both Contracting States, its status is determined as follows:

a) it is considered resident of that State in which it has the permanent residence;

b) if person has the permanent residence in both States or if it has no the permanent residence in one of the States, it is considered resident of that State which citizen is;

c) if each of Contracting States considers it as the citizen or if it is not citizen of any of them, then competent authorities of Contracting States resolve this issue by mutual consent.

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