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AGREEMENT BETWEEN THE RUSSIAN FEDERATION AND GRAND DUCHY OF LUXEMBOURG

of June 28, 1993

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

(Protocol as amended of 21.11.2011)

The Russian Federation and the Grand Duchy of Luxembourg, wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and property, agreed as follows:

Article 1. Persons to whom the Agreement is applied

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

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income and property levied by Contracting States, their policy - administrative divisions or regional authorities, irrespective of method of their collection.

2. This agreement extends to the following taxes levied in Contracting States:

a) in the Grand Duchy of Luxembourg:

(i) the income tax on physical persons (l "impot sur le revenu des personnes physiques);

(ii) tax on corporations (l "impot sur le revenu des collectivites);

(iii) capital tax (l "impot sur la fortune); and

(iv) municipal sales tax (l "impot commercial communal)

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

b) in 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

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

3. This agreement is applied also to any taxes, in essence similar listed in Item 2, which will be levied after signature date of the Agreement in amendment or instead of the taxes specified in Item 2. Competent authorities of Contracting States will notify each other on any essential changes in their tax laws.

Article 3. General determinations

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

a) expression "one Contracting State" or "other Contracting State" means the Russian Federation (Russia) or the Grand Duchy of Luxembourg (Luxembourg), depending on context;

b) the term "Russia" means the Russian Federation. When using in geographical sense the term "Russia" includes the territorial sea, and also economic zone and the continental shelf concerning which the Russian Federation can perform the sovereign rights and jurisdiction according to international law and in which the tax legislation of the Russian Federation is effective;

c) the term "Luxembourg" means the Grand Duchy of Luxembourg. When using in geographical sense the term "Luxembourg" means the territory of the Grand Duchy of Luxembourg;

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

e) the term "company" means any legal entity or any other consolidation which for the tax purposes is considered as the legal entity;

f) expression "international delivery" means any transportation sea, river either the aircraft or any other vehicle operated by person with the permanent residence in one Contracting State, except as specified, when it is transported between the Items located in other Contracting State;

g) expression means "competent authority":

(I) in relation to Russia - the Ministry of Finance of the Russian Federation or the representative authorized by it;

(II) in relation to Luxembourg - the Minister of Finance and the representative authorized by it.

2. In case of application of this agreement by the Contracting State any term which is not determined in the Agreement has that significance which is attached to it by the legislation of this State concerning taxes to which the Agreement extends if other does not follow from context.

Article 4. Persons with the permanent residence

1. In case of application of this agreement expression "person with the permanent residence in the Contracting State" means any person who based on the legislation of this State is assessed with tax in this State on the basis of its residence, place of registration, management or any other similar criterion.

2. In case according to Item 1 provisions the physical person is person with the permanent residence in both Contracting States, its provision is determined as follows:

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