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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE KINGDOM OF MOROCCO

of September 4, 1997

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

Government of the Russian Federation and Government of the Kingdom of Morocco,

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 extends to taxes on the income and property levied on behalf of each Contracting State irrespective of method of their collection.

2. All taxes levied from total of income, total cost of property or on 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 on property.

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

a) concerning Morocco:

(i) tax on the companies;

(ii) general tax on the income, including tax on the professional and land income exempted from general tax on the income;

(iii) the stockholder's tax or shares and the income equated to them;

(iv) tax on the income from real estate;

(v) fee in fund of national solidarity;

(vi) tax on the fixed income from sales of products; and

(vii) the income tax from alienation of shares and shares;

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

b) concerning Russia - the taxes levied according to the following Laws:

(i) "About the income tax of the companies and organizations";

The law of the Russian Federation of 27.12.1991 No. 2116-1 "About the income tax of the companies and organizations" ceased to be valid since January 1, 2002 in connection with adoption of the Federal Law of the Russian Federation of 06.08.2001 No. 110-FZ, except separate provisions which void in special procedure.

Since January 1, 2002 the questions concerning collection of the income tax of the organizations are regulated by Chapter 25 of the Tax Code of the Russian Federation.

(ii) "About the income tax from physical persons";

(iii) "About the property tax of the companies";

(iv) "About the property tax of physical persons";

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

4. The agreement is applied also to any to similar or in essence to similar taxes which will be established after signature date of the Agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on the 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 "one Contracting State" and "other Contracting State" mean, depending on context, Russia or Morocco;

b) Morocco means the territory of the Kingdom of Morocco, and also its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law;

c) Russia 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;

d) the term "person" includes physical persons, the companies, the companies and any other associations of persons;

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

f) the term "national persons" means any physical person which has nationality of one Contracting State according to the current legislation of this State;

g) the term means "competent authority":

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