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

of December 20, 2010

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

Government of the Russian Federation and Government of the Republic of Latvia,

wishing to sign the Agreement on avoidance of double taxation and on prevention of tax avoidance concerning taxes on the income and the capital and for the purpose of strengthening 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 on the capital levied on behalf of the Contracting State, or its political divisions or municipal authorities irrespective of method of their collection.

2. All taxes levied from total of income, the general capital or from elements of the income or the capital including taxes on the income from alienation of personal or real estate, and also taxes on the income from capital gain are considered as taxes on the income and on the capital.

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

a) in relation to the Russian Federation:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations; and

(iv) property tax of physical persons;

b) in relation to the Republic of Latvia:

(i) corporate income tax;

(ii) the income tax from physical persons; and

(iii) non-personal tax.

4. This agreement is applied also to any to similar or in essence to similar taxes which will be levied from the income or from the capital after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on any essential changes made to their corresponding tax legislation.

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 Latvia depending on context;

b) the term "Russian Federation" means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf determined according to international law including the Convention of the United Nations on maritime law of 1982;

c) the term "Republic of Latvia" means the territory of the Republic of Latvia, and also its exclusive economic zone and the continental shelf determined according to international law including the Convention of the United Nations on maritime law of 1982;

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 is considered for the tax purposes 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, air, automobile or the rail vehicle operated by the company of the Contracting State except cases when sea, air, automobile or the rail vehicle is operated only between Items in other Contracting State;

h) the term means "competent authority":

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

(ii) in relation to the Republic of Latvia - the Ministry of Finance or its authorized representative;

i) the term "national person" means:

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

(ii) any legal entity, partnership or association which received such status according to the current legislation of the Contracting State.

2. In case of application by the Contracting State of this agreement any term which is not determined in it has that value if other which it has according to the legislation of this State concerning taxes to which this agreement, and any value which this term has in the corresponding tax legislation of this State is applied does not follow from context has priority over any value which it can have in other laws of this State.

Article 4. Resident

1. For the purposes of this agreement the term "resident of the Contracting State" means any person who by the legislation of this State is subject to the taxation in it based on its residence, the permanent residence, the place of management, place of registration or any other criterion of similar nature, and also includes this State and any its political division or municipal authority. However this term does not include any person who is subject to the taxation in this State only concerning the income from sources in this State or concerning the capital which is in this State.

2. If according to Item 1 provisions the physical person is resident of both Contracting States, then its status is determined as follows:

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