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of April 24, 2013

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

(Protocol as amended of 01.10.2020)

The government of the Russian Federation and the Government of Malta, wishing to sign the Convention on avoidance of double taxation and on prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the Convention extends

This Convention is applied to persons which are residents of one or both Contracting States.

Article 2. Taxes to which the Convention extends

1. This Convention is applied to the taxes on the income levied on behalf of the Contracting State, its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income or separate elements of the income including taxes on the income from alienation of personal or real estate and taxes on the total amount of the salary paid by the companies are considered as taxes on the income.

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

a) in relation to Malta:

tax on the income

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

b) in relation to Russia:

(i) income tax of the organizations;

(ii) income tax

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

4. The convention is applied also to any identical or in essence to similar taxes or to those taxes which are levied after signing of the Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on any essential changes made to their tax legislation.

Article 3. General determinations

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

a) the term "Malta" means the Republic of Malta and when using in geographical sense means the island of Malta, the island Gozo and other islands of the Maltese archipelago, including their territorial waters, and also any site of seabed, its subsoil and water thickness over it concerning which Malta performs the sovereign rights, jurisdiction or control according to international law and the national legal system, including the legislation concerning investigation of the continental shelf and development of its natural resources;

b) the term "Russia" means the Russian Federation and when using in geographical sense means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law (1982);

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

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

e) the term "company" means any corporate consolidation or any other education considered for tax purposes as corporate consolidation;

f) the terms "company of the 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 or the aircraft operated by the company of the Contracting State except cases when such sea or the aircraft is used only for transportation between Items in other Contracting State;

h) the term "business activity" includes rendering professional services and other activities of independent nature;

i) the term means "competent authority":

(i) in relation to Malta: Minister of Finance or his authorized representative; and

(ii) in relation to the Russian Federation: Ministry of Finance or its authorized representative;

j) the term "national person" in relation to the Contracting State means:

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

(ii) any legal entity, partnership or association founded according to the legislation of this Contracting State.

2. In case of application of this Convention at any time by the Contracting State any term which is not determined in it has that significance (if other does not follow from context), which is attached to it at the moment by the legislation of this State concerning taxes to which this Convention is applied, and interpretation which is given to the term by the tax legislation of this State will prevail over the interpretation given by other laws of this State.


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