THE AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE KOREAN IS NATIONAL - THE DEMOCRATIC REPUBLIC

of September 26, 1997

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

The government of the Russian Federation and the Government Korean Is national - the Democratic Republic, 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 in each Contracting State irrespective of method of their collection.

2. As taxes on the income and the capital all taxes levied from the total amount of the 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, and also taxes levied from the income from increase in capital value will be considered.

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

a) in the Korean K KK Democratic Republic (DPRK):

(i) the income tax from the companies;

(ii) the income tax from physical persons;

(iii) property tax;

(iv) succession duty

(further referred to as as "tax DPRK");

b) in 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;

(iv) property tax of physical persons

(further referred to as as "The Russian tax").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied in addition to the existing taxes or instead of them after signature date of the Agreement. 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 term "The Korean It Is National — the Democratic Republic (KIINDR)" means the territory Korean Is national - the Democratic Republic, and also its continental shelf and exclusive economic zone determined according to the Convention of the UN on maritime law;

b) the term "Russian Federation (Russia)" means the territory of the Russian Federation, and also its continental shelf and exclusive economic zone determined according to the Convention of the UN on maritime law;

c) the terms "Contracting State", "one Contracting State" and "other Contracting State" mean DPRK or Russia depending on context;

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 are considered as corporate consolidation for the purposes of the taxation;

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 "national person" means:

i) any physical person having nationality of the Contracting State;

ii) any legal entity, partnership or association which received the status based on the current legislation of the Contracting State;

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

i) the term means "competent authority":

i) in relation to DPRK - the Ministry of Finance or its authorized representative;

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