Document from CIS Legislation database © 2003-2019 SojuzPravoInform LLC

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

of December 5, 1998

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

(In edition of the Protocol of 07.10.2010)

The government of the Russian Federation and the Government of the Republic of Cyprus, wishing to sign the Agreement on avoidance of double taxation 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 each Contracting State or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income, total cost 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 levied from the total amount of the salary paid by the company and also taxes on the income from capital gain are considered as taxes on the income and the capital.

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

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

(iv) property tax of physical persons

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

b) in relation to Cyprus:

(i) income tax,

(ii) the corporate tax on the income,

(iii) special collection on protection of the Republic,

(iv) non-personal tax, and

(v) capital gain tax

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

4. This agreement is applied also to any to similar or in essence to similar taxes on the income and the capital, collectable by any of Contracting States 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 or the Republic of Cyprus, 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 international law;

c) the term "Republic of Cyprus" means the territory of the Republic of Cyprus and includes its exclusive economic zone and the continental shelf determined according to international law;

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

e) 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;

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

g) the term "international delivery" means any transportation sea either the aircraft, or the road transportation operated by resident of one Contracting State except cases when such transport is operated only between Items in other Contracting State;

h) the term "national person" means;

(i) any physical person having nationality

Contracting state; and

(ii) any person which is not physical person

received the status according to operating

legislation of the Contracting State;

i) the term means "competent authority":

(i) in relation to the Russian Federation - the Ministry

finance of the Russian Federation or his representative

representative;

(ii) in relation to the Republic of Cyprus - the Minister of Finance

or his authorized representative.

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