AGREEMENT BETWEEN THE RUSSIAN FEDERATION AND STATE OF KUWAIT

of February 9, 1999

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

Government of the Russian Federation and Government of the State of Kuwait,

wishing to promote development of the economic relations by agreement signature about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the capital,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who 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 and on 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 the total amount of the income, total amount 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 capital gain taxes are considered as taxes on the income and on the capital.

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

a) in the Russian Federation:

(1) income tax (income) of the companies and organizations;

(2) income tax;

(3) property tax of the companies; and

(4) property tax of physical persons

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

b) in the State of Kuwait:

(1) corporate income tax;

(2) the fee from net profit of the Kuwaiti joint stock companies paid to the Kuwaiti fund of development of science (KFAS);

(3) Decline

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

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

Article 3. General determinations

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

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

b) the term "Russian Federation (Russia)" 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;

c) the term "State of Kuwait" means the territory of the State of Kuwait, including any area outside the territorial sea which, according to international law, is determined or can be determined, by the laws of the State of Kuwait as the area over which the State of Kuwait can perform the sovereign rights or jurisdiction;

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

e) the term "national person" means:

(1) in relation to the Russian Federation any physical person having citizenship of the Russian Federation or, in relation to the State of Kuwait, nationality of the State of Kuwait; and

(2) any legal entity, partnership, association or other education which received such status on the basis of the laws existing in the Contracting State;

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

g) 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;

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

i) the term "tax" means, depending on context, the Russian tax or the Kuwaiti tax;

j) the term means "competent authority":

(1) in relation to the Russian Federation: Ministry of Finance of the Russian Federation or his authorized representative;

(2) in relation to the State of Kuwait: Minister of Finance or authorized representative of the Minister of Finance.

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