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

of June 24, 1994

About avoidance of double taxation of the income and property

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

being guided by the aspiration to sign the Agreement on avoidance of double taxation of the income and property,

agreed as follows.

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are persons with the permanent residence or the permanent residence in one or in both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income and property levied in each of Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income on total cost of property or from their separate elements, including taxes on the income from alienation of personal and real estate belong to taxes on the income and property.

3. The operating taxes to which this agreement extends include:

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

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

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

iii) "About the property tax of the companies";

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

b) in relation to the Slovak Republic:

i) tax on the income of physical persons;

ii) tax on the income of legal entities;

iii) the real estate tax (further the referred to as "Slovak taxes")

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