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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE ARAB REPUBLIC OF EGYPT

of September 23, 1997

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

The government of the Russian Federation and the Government of the Arab Republic of Egypt, wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital and for the purpose of encouragement of economic cooperation between two countries, 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 the capital levied on behalf of the Contracting State or its political division or regional authority irrespective of collection method.

2. All taxes levied from total of income, the 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, taxes on the total amount of the salary, and also taxes on the income from increase in capital value are considered as taxes on the income and the capital.

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

a) in relation to 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 organizations;

(iv) property tax of physical persons

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

b) in relation to the Arab Republic of Egypt:

(i) tax on income gained from real estate (including the agricultural land tax, tax on buildings);

(ii) the unified income tax from physical persons;

(iii) tax on corporate profit;

(iv) charges on development of financial resources of the State;

(v) the additional taxes levied in the form of percent from the amount of the taxes mentioned above, or otherwise

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

4. This agreement is applied also to any to similar or in essence to the similar taxes on the income and the capital levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws.

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 (Russia) or the Arab Republic of Egypt (Egypt), depending on context;

b) 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;

c) the term "Arab Republic of Egypt" means the territory of the Arab Republic of Egypt, including the overland territory, the territorial sea, and also the exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law of 1982;

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

e) the term "company" means any corporate consolidation or any education which is considered as corporate consolidation for the tax purposes;

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, river or the aircraft operated by the company of one Contracting State except cases when sea, river or the aircraft is operated only between Items in other Contracting State;

h) the term means "competent authority":

(i) in relation to Russia - the Ministry of Finance of the Russian Federation or his authorized representative;

(ii) in relation to Egypt - the Minister of Finance or his authorized representative;

i) the term "national person" means:

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