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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE UNITED MEXICAN STATES

of June 7, 2004

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of the United Mexican States, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income, and also for the purpose of development 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 established in each of Contracting States according to the legislation of these Contracting States irrespective of method of their collection.

2. The existing taxes to which this agreement extends are:

a) in relation to the Russian Federation:

(i) tax on the income (profit) of the companies and organizations;

(ii) the income tax from physical persons

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

b) in relation to the United Mexican States:

(i) income tax

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

3. This agreement is applied also to any identical or in essence to similar taxes on the income 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 the essential changes made to their relevant tax laws.

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 Russia or Mexico depending on context;

b) the term "Russian Federation (Russia)" means the territory of the Russian Federation and includes its exclusive economic zone and the continental shelf where the Russian Federation performs the sovereign rights and jurisdiction according to the Convention of the UN on maritime law of 1982;

c) the term "Mexico" means the territory of the United Mexican States according to the determinations this in their Political Constitution including their exclusive economic zone and the continental shelf where the United Mexican States perform the sovereign rights and jurisdiction according to the Convention of the UN 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 education or any consolidation which for the tax purposes is considered 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 or the aircraft operated by the company of the Contracting State except cases when sea or the aircraft is operated only between Items in other Contracting State;

h) the term means "competent authority":

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

(ii) in relation to Mexico - the Ministry of Finance and the public credit;

i) the term "national person" means:

(i) in relation to Russia:

- any person having citizenship of Russia;

- any legal entity, partnership and association who received such status based on the current legislation of Russia;

(ii) in relation to Mexico:

- any physical person having citizenship of Mexico;

- any legal entity, partnership and association who received such status based on the current legislation of Mexico.

2. In case of application of this agreement by the Contracting State any term which is not determined in it has that value if other which is given it at the moment by the legislation of this State does not follow from context. In case of discrepancy between the determination of any term provided by the laws concerning taxes to which this agreement is applied and the determination provided by any other Section of the legislation of this State the first mentioned determination will be applied.

Article 4. Resident

1. For the purposes of this agreement the term "resident of the Contracting State" means any person who according to the legislation of this State is subject in it to the taxation based on its residence, the permanent residence, the place of management, place of registration or any other criterion of similar nature, and includes this State, its any political division and regional 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.

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

a) it is considered resident of that State in which it has permanent housing; if it has permanent housing in both States, it is considered resident of that State in which it has more close personal and commercial relations (the center of vital interests);

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