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

of October 21, 1997

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

The government of the Russian Federation and the Government of the Republic of Macedonia, wishing to sign the Agreement on avoidance of double 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 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 property levied in each Contracting State irrespective of method of their collection.

2. All taxes levied from total of income, the total amount of property or from separate elements of the income or property including taxes on the income from alienation of personal or real estate, and also the property increment value duties are considered as taxes on the income and property.

3. Taxes to which the Agreement is applied, in particular, are:

1) 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 taxes of physical persons

(further the referred to as "Russian taxes");

2) in the Republic of Macedonia:

(i) income tax;

(ii) income tax;

(iii) property tax

(further the referred to as "Macedonian taxes").

4. This agreement is applied also to any to similar or in essence to similar taxes which are levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on 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:

1) the terms "Contracting State" and "other Contracting State" mean the Russian Federation or the Republic of Macedonia depending on context;

2) the terms "Russian Federation" and "Republic of Macedonia" mean the territories over which each of Contracting States has sovereignty according to the national legal system and international law, and in relation to the Russian Federation includes its exclusive economic zone and the continental shelf;

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

4) the term "company" means any corporate consolidation or any education which for the tax purposes is considered as corporate consolidation;

5) 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;

6) the term "international delivery" means any transportation sea, the aircraft or the road vehicle operated by the company which is resident of one Contracting State, except cases when sea, the aircraft or the road vehicle is operated only between the Items located in other Contracting State;

The term "competent authority" means 7):

i) in the Russian Federation - the Ministry of Finance of the Russian Federation or his authorized representative; and

ii) in the Republic of Macedonia - the Ministry of Finance of the Republic of Macedonia or his authorized representative;

8) the term "national person" means any physical person having nationality of the Contracting State and any legal entity, partnership or association which received such status on the basis of the laws existing in this Contracting State.

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

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