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of November 15, 1995

About avoidance of double taxation concerning taxes on the income and the capital

(In edition of the Protocol of 24.09.2011)

The government of the Russian Federation and Federal Council of the Swiss Confederation, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and the capital,

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

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

- in the Russian Federation:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations and

(iv) the property tax of physical persons (further referred to as "the Russian tax");

- in Switzerland:

federal taxes, taxes of cantons and communes (communities)

(i) on the income (total income, the salary, capital revenue, the entrepreneurial income, capital gain and other income types); and

(ii) on the capital (total amount of property, personal and real estate, assets, the paid-in capital and reserves, and other types of the capital)

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

4. This agreement is applied also to all to similar or in essence to similar taxes which after signature date of the Agreement will be levied in amendment or instead of the existing taxes. Competent authorities of both Contracting States will notify each other on any essential changes in their corresponding tax legislation.

Article 3. General determinations

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

a) expressions "Contracting state" and "other Contracting State" mean the Russian Federation or Switzerland depending on context;

b) expression "the Russian Federation (Russia)", when using in geographical sense, means its territory, including internal waters and the territorial sea, airspace over them, and also exclusive economic zone and the continental shelf where the Russian Federation performs the sovereign rights and jurisdiction according to its domestic legislation and rules of international law;

the term "Switzerland" means the Swiss Confederation;

c) expression means "political division":

- in relation to the Russian Federation, subjects or others it is administrative - territorial educations;

- in relation to Switzerland, Cantons;

d) the term "person" includes any 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) expressions "the company of one Contracting State" and "the 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) expression "international delivery" means any transportation sea or the aircraft operated by the company of one Contracting State except cases when sea or the aircraft is operated only between Items in other Contracting State;

h) expression means "competent authority":

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

- in relation to Switzerland, the Director of Federal Tax Administration or its authorized representative;

i) expression means "national person":

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

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