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

of December 15, 1997

About avoidance of double taxation concerning taxes on the income

Government of the Russian Federation and Government of the Republic of Turkey,

being guided by the aspiration to sign the Agreement on avoidance of double taxation concerning taxes on the income and for the purpose of development of economic cooperation between both States,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are, from the point of view of the taxation, persons with the permanent residence and residence in one or in both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement extends to taxes on the income levied in the Contracting State irrespective of method of their collection.

2. As taxes on the income all taxes levied from total of income or from its separate elements including the income from alienation of personal and real estate will be considered.

3. The existing taxes to which this agreement extends, in particular, are:

a) in relation to the Russian Federation - the income taxes and the income levied according to the following Laws of the Russian Federation:

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

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

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

b) in relation to the Republic of Turkey:

(i) income tax (Gelir Vergisi),

(ii) tax on corporations (Kurumlar Vergisi),

(iii) the collection levied from the income tax and tax on corporations

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

4. This agreement will be applied also to any identical or in essence to similar taxes on the income which will be 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 any essential changes in their relevant tax laws necessary for application of this agreement.

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, the Russian Federation (Russia) or the Republic of Turkey (Turkey);

b) the terms "Russian Federation" and "Republic of Turkey" mean their territories, the territorial seas, and also their continental shelves and exclusive economic zones determined according to international law;

c) the term "tax" means any tax to which Article 2 of this agreement extends;

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

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

f) the term "the registered office" means, in relation to Turkey, legally registered head office according to the Trade code of Turkey;

g) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively the business activity performed by person with the permanent residence in one Contracting State and the business activity performed by person with the permanent residence in other Contracting State;

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