THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE REPUBLIC OF KOREA

of November 19, 1992

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of the Republic of Korea, being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both States, and for the purpose of avoidance of double taxation concerning taxes on the income, agreed as follows.

Article 1. Persons to whom the Convention is applied

This Convention is applied to persons who are persons with the permanent residence in one or in both Contracting States.

Article 2. Taxes to which the Convention extends

1. This Convention extends to the taxes on the income or part of total income levied according to the legislation of each of Contracting States irrespective of method of their collection.

2. Taxes to which this Convention extends are:

a) in relation to the Russian Federation - the income taxes and the income levied according to the Laws of the Russian Federation "About the income tax of the companies and organizations", "About the taxation of the income of banks", "About the taxation of the income from insurance activity" and "About the income tax from physical persons" (the "Russian taxes" which are referred to as further);

b) in relation to the Republic of Korea - the income tax, tax on the corporations and tax on residents levied according to the laws of the Republic of Korea (the "Korean taxes" which are referred to as further).

3. This Convention will be applied also to any identical or in essence to the similar taxes provided in Item 2 of this Article which will be levied after signature date of this Convention in amendment or instead of the existing taxes mentioned in Item 2 of this Article. Competent authorities of Contracting States will notify each other on any essential changes in their tax legislations.

Article 3. General determinations

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

a) the terms "one Contracting State" and "other Contracting State" mean, depending on context, the Russian Federation (Russia) or the Republic of Korea;

b) the term "Russian Federation" when using in geographical sense means its territory, including territorial waters, and also economic zone and the continental shelf where this State performs the sovereign rights and jurisdiction according to rules of international law and in which its tax legislation is effective;

c) the term "Republic of Korea" when using in geographical sense means its territory, including the territorial sea, and also economic zone and the continental shelf where this State can perform for particular purposes the sovereign rights and jurisdiction according to rules of international law and in which its tax legislation is effective;

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

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

f) the term "international delivery" means any transportation by means of sea, river, aircrafts and any other vehicles, performed by person with the permanent residence in the Contracting State, is exclusive between the Items located in different Contracting States;

g) the term means "competent authority":

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