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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF SYRIAN ARAB REPUBLIC

of September 17, 2000

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of the Syrian Arab Republic, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income, 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 levied on behalf of the Contracting State or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal or real estate, and also capital gain taxes are considered as taxes on the income.

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

a) in the Russian Federation:

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

(ii) the income tax from physical persons

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

b) in Syria:

(i) tax on income gained from business, industrial and non-commercial (liberal professions) activity;

(ii) the income tax on the salary and salary;

(iii) the income tax from nonresidents;

(iv) tax on income gained from use of personal estate; and

(v) the additional taxes levied now or in the future in the form of percent from above-mentioned taxes either in any other form or at any other rate

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

4. This agreement is applied also to any to similar or in essence to the similar taxes 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.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

a) the term "Russian Federation" means the territory of the Russian Federation. The term also means the Russian exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law of 1982;

b) the term "Syria" means the territory of the Syrian Arab Republic. The term also means the Syrian exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law of 1982;

c) the term "political division" is used only in relation to the Russian Federation and means educations according to the legislation or any other administrative-territorial educations;

d) the terms "one Contracting State" and "other Contracting State" mean the Russian Federation or Syria, depending on context;

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

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

g) the terms "company of one Contracting State" and "company of other Contracting State" mean the company registered in the Contracting State and/or managed by resident of this Contracting State;

h) the term "national person" means:

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association which received such status based on the current legislation of the Contracting State;

i) the term "international delivery" means any transportation sea or the aircraft operated by the company which actual governing body is located in the Contracting State, except cases when sea or the aircraft is operated only between the Items located in other Contracting State;

j) the term means "competent authority":

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