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of March 12, 1999

About avoidance of double taxation and prevention of tax avoidance on the income

The government of the Russian Federation and the Government of the Republic of Indonesia, wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance on the income,

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 levied on behalf of one of Contracting States irrespective of method of their collection.

2. As taxes on the income all taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal or real estate will be considered.

3. Taxes to which this agreement extends are:

a) in relation to the Russian Federation:

(i) income tax of the companies and organizations;

(ii) the income tax from physical persons

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

b) in relation to the Republic of Indonesia:

the income tax levied according to Undang-undang Pajak Penghasilan of 1984 (The law No. 7 of 1983 with changes)

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

4. This agreement is applied also to similar or in essence to the similar taxes levied after signature date of the Agreement in amendment or instead of the taxes mentioned in Item 3. 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 Republic of Indonesia (Indonesia);

b) the term "Russia" 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 "Indonesia" means the territory of the Republic of Indonesia as it is determined according to its legislation, and also its exclusive economic zone and the continental shelf where the Republic of Indonesia performs the sovereign rights and jurisdiction according to international law;

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

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

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

h) the term means "competent authority":

- in relation to the Russian Federation - the Ministry of Finance or its authorized representative;

- in relation to Indonesia - the Minister of Finance or his authorized representative;

i) the term "citizen" means any physical person having nationality of the Contracting State.


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