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

of June 8, 1993

About avoidance of double taxation concerning taxes on the income and property

The government of the Russian Federation and the Government of the Republic of Bulgaria, confirming the desire to expand and promote mutual cooperation taking into account interests of both parties, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and property, agreed as follows.

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are from the point of view of the taxation persons with the permanent residence in one or in both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement extends to the taxes on the income and property levied in Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income, total cost of property or from separate elements of the income and property including the income from alienation of personal or real estate are considered as taxes on the income and property.

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

a) in relation to the Russian Federation - the income taxes, the income and property levied according to the following Laws of the Russian Federation:

The law of the Russian Federation of 27.12.1991 No. 2116-1 "About the income tax of the companies and organizations" ceased to be valid since January 1, 2002 in connection with adoption of the Federal Law of 06.08.2001 No. 110-FZ, except separate provisions which void in special procedure.

Since January 1, 2002 the questions concerning collection of the income tax of the organizations are regulated by Chapter 25 of the Tax Code of the Russian Federation.

(i) "About the income tax of the companies and organizations",

(ii) "About the taxation of the income of banks",

(iii) "About the taxation of the income from insurance activity",

(iv) "About the income tax from physical persons",

(v) "About the property tax of the companies" and

(vi) "About the property tax of physical persons"

(the "Russian taxes" which are referred to as further);

b) in relation to the Republic of Bulgaria

(i) tax on total income,

(ii) income tax and

(iii) tax on buildings

(further the referred to as "Bulgarian taxes").

4. This agreement will be applied also to any identical or in essence to similar taxes on the income which will be levied after signature date of this Agreement in amendment or instead of the existing taxes. According to article 26 provisions competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws necessary for application of this agreement.

Article 3. General determinations

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

a) expressions "one Contracting State" and "other Contracting State" mean, depending on context, the Russian Federation (Russia) or the Republic of Bulgaria;

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