PROTOCOL TO THE 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 parties agreed that following provisions constitute integral part of the Agreement:

1. To Article 5:

In case of application of Item 3 the moments of the beginning and completion of the building site, assembly or assembly object are determined by the dates fixed jointly by customer representatives and the contractor in the protocol or other document provided by terms of the contract.

2. To Article 13:

As criteria of permanent base of the Party will apply the criteria of permanent mission stated in Article 5.

At the same time, expression "the permanent base" does not include types of activity (others, than are specified in Article 14) as a result of which implementation the total amount of annual earnings does not exceed the two hundredfold sum of the average minimum monthly salary determined by the legislation of the Contracting State in the territory of which these activities within the corresponding calendar year are performed.

Competent authorities of Contracting States by mutual consent establish procedure for collection of taxes in such cases.

2.1. To Article 8:

Irrespective of provisions of this Article the income of representative offices of airlines of one Contracting State which is in other Contracting State from the activities of agency nature connected with international carriages can be assessed with tax in this other State.

3. To Article 26:

Provisions of this Article will be applied irrespective of operation of the Agreement between the Government of the Russian Federation and the Government of the Republic of Armenia about cooperation and mutual aid concerning observance of the tax legislation signed in Moscow on March 11, 1994.

It is made in Moscow on December 28, 1996 in duplicate, in the Russian and Armenian languages, and both texts are equally authoritative.

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It is ratified by Federal Assembly (The Federal Law of December 17, 1997 N 151-FZ - the Russian Federation Code, 1997, N 51, the Art. 5717).

The agreement became effective on March 17, 1998.

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