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

of September 9, 2002

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

(Protocol as amended of 17.11.2015)

The government of the Russian Federation and the Government of the Republic of Singapore, wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and for the purpose of assistance to economic cooperation between two countries,

agreed about the following:

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 levied in each Contracting state according to the legislation of each Finishing speaking state, irrespective of method of their collection.

2. All taxes levied from total income or from income elements including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

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

a) in relation to the Russian Federation:

(i) income tax of the organizations;

(ii) income tax

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

b) in relation to Singapore:

- income tax

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

4. 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 any 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 the Russian Federation (Russia) or Singapore, depending on context;

b) the term "Russian Federation" means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf over which the Russian Federation performs the sovereign rights and jurisdiction determined according to the Convention of the United Nations on maritime law of 1982;

c) the term "Singapore" means the Republic of Singapore and when using in geographical sense includes its overland territory, internal waters and the territorial sea, and also any sea space outside the territorial sea which was determined or can be determined in the future according to its legislation and international law concerning which Singapore has sovereign rights or jurisdiction over sea space, seabed, subsoil and natural resources;

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

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

f) the term "company of one Contracting state" and "company of other Contracting state" means 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 are operated only between Items in other Contracting state;

h) the term "national person" means:

i) all physical persons having nationality of the Contracting state

ii) all legal entities, partnerships and associations which received such status based on the current legislation of the Contracting state;

i) the term means "competent authority":

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

ii) in relation to Singapore - the Minister of Finance or his authorized representative.

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 by the legislation of this state concerning taxes to which this agreement is applied does not follow from context.

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