of November 27, 1995
About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income
The government of the Russian Federation and the Government Is southern - the African Republic,
being guided by the aspiration to encourage and strengthen the relations between two States,
agreed as follows:
This agreement is applied to persons who are persons with the permanent residence in one or in both Contracting States.
1. This agreement is applied to the taxes on the income levied in the Contracting State irrespective of method of their collection.
2. All taxes levied from total of income or from separate elements of the income 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 extends, in particular, are:
a) in Russia - the taxes levied according to the following laws of the Russian Federation:
(i) "About the income tax of the companies and organizations";
(ii) "About the income tax from physical persons"
(further referred to as "the Russian tax");
b) in South Africa:
(i) normal tax;
(ii) tax on shareholders - nonresidents;
(iii) secondary tax on the companies
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The law of the Russian Federation of 27.12.1991 No. 2116-1 "About the income tax of the companies and organizations" ceased to be valid since January 1, 2002 in connection with adoption of the Federal Law of the Russian Federation of 06.08.2001 No. 110-FZ, except separate provisions which void in special procedure.
Since January 1, 2002 the questions concerning collection of the income tax of the organizations are regulated by Chapter 25 of the Tax Code of the Russian Federation.