of May 22, 1992
About avoidance of double taxation of the income and property
Government of the Russian Federation and Government of the Republic of Poland,
being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both States,
and for the purpose of avoidance of double taxation of the income and property,
decided to sign this agreement and agreed as follows:
1. This agreement is applied to persons who are persons with the permanent residence in one or in both Contracting States.
2. For the purposes of this agreement the term "person with the permanent residence in one Contracting State" means any person or any education which, by the legislation of this State, is subject in it to the taxation on the basis of the residence, the permanent place of stay, place of registration as the legal entity or any other similar criterion.
If the income turns out complete partnership, the permanent residence is determined according to the permanent residence of person, taxable concerning such income.
3. If according to Item 2 provisions person which is not physical person is person with the permanent residence in both Contracting States, it is considered face with the permanent residence in that Contracting State in which its actual governing body is located.
4. If according to Item 2 provisions the physical person is person with the permanent residence in both Contracting States, its provision is determined as follows:
a) it is considered face with the permanent residence in that Contracting State in which it has the permanent dwelling; if it has the permanent dwelling in both Contracting States, it is considered face with the permanent residence in that Contracting State in which it has the most close personal and commercial relations (the center of vital interests);
b) if the State in which it has the center of vital interests cannot be determined or if it has no the permanent dwelling in one of Contracting States, it is considered face with the permanent residence in that State in which it usually stays;
c) if it usually lives in both Contracting States or if it usually does not live in one of them, it is considered face with the permanent residence in that Contracting State which citizen it is;
d) if each of Contracting States considers it as the citizen or any of the States does not consider it that, competent authorities of Contracting States resolve the matter by mutual consent.
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