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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE'S REPUBLIC OF CHINA

of January 18, 2016

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

Government of the Russian Federation and Government of Hong Kong Special Administrative Region of People's Republic of China,

wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the Agreement extends

This agreement extends to persons who are residents of one or both Contracting Parties.

Article 2. Taxes to which the Agreement extends

1. This agreement extends to taxes on the income levied on behalf of the Contracting Party, its political divisions or regional authorities irrespective of method of their collection.

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

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

a) in relation to Hong Kong Special Administrative Region:

(i) income tax;

(ii) wage tax;

(iii) property tax;

irrespective of their charge according to personal assessment (personal assessment);

b) in relation to Russia:

(i) income tax of the organizations;

(ii) income tax.

4. This agreement is applied also to any identical or in essence to similar taxes which are established after signature date of this agreement in amendment or instead of the existing taxes, and also to any other taxes which the Contracting Party can establish in the future according to Items 1 and 2 of this Article. Competent authorities of Contracting Parties will notify each other on any essential changes which are made to their tax laws.

5. The existing taxes and taxes established after the signature of this agreement hereinafter are referred to as further "the Russian tax" or "tax of Hong Kong Special Administrative Region" depending on context.

Article 3. General determinations

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

a) (i) the term "Hong Kong Special Administrative Region" means any area to which the tax laws of Hong Kong Special Administrative Region of People's Republic of China extend;

(ii) the term "Russia" means the Russian Federation and in case of application in geographical sense means all territory of the Russian Federation, including internal waters and the territorial sea to which extend the Russian laws concerning the taxation and also its exclusive economic zone and the continental shelf over which the Russian Federation performs the sovereign rights and jurisdiction determined according to the Convention of the United Nations on maritime law (1982);

b) the term "company" means any corporate consolidation or any education considered as corporate consolidation for the purposes of the taxation;

c) the term means "competent authority":

(i) in relation to Hong Kong Special Administrative Region - the Head of the Internal revenue service or his authorized representative;

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

d) the term "Contracting Party" or "Party" means the Russian Federation or Hong Kong Special Administrative Region depending on context;

e) the terms "company of one Contracting Party" and "company of other Contracting Party" mean respectively the company managed by resident of one Contracting Party and the company managed by resident of other Contracting Party;

f) the term "permanent base" means the permanent place which the resident of the Contracting Party takes in other Contracting Party for the purposes of rendering independent personal services;

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

h) the term "national person" in relation to Russia means:

(i) any physical person having citizenship of Russia;

(ii) any legal entity, partnership or association founded according to the current legislation of Russia; and

(i) the term "person" includes physical person, the company and any other consolidation of persons and in relation to Hong Kong Special Administrative Region also includes trust and partnership.

2. In this agreement the terms "Russian tax" and "tax of Hong Kong Special Administrative Region" do not include any penalty or percent added according to the legislation of any of Contracting Parties concerning taxes to which this agreement according to Article 2 extends.

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