AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE UNITED ARAB EMIRATES

of December 7, 2011

About income assessment from investments of contracting states and their financial and investment institutions

Government of the Russian Federation and Government of the United Arab Emirates,

wishing to develop and strengthen economic and financial cooperation between them, and also cooperation in the field of investments,

recognizing that provision of mutual tax benefits to the public financial and investment institutions will promote further development of the existing strategic partnership and increase in capital movement between two countries,

agreed as follows:

Article 1

1. Taxes to which this agreement extends, in particular, are:

a) in the Russian Federation:

income tax of the organizations;

b) in the United Arab Emirates:

(i) tax on corporations,

(ii) the income tax, including provincial taxes on the income levied in each of the Emirates.

2. This agreement is also applied to any identical or in essence to similar taxes which are established by any of Contracting states after signature date of this agreement in amendment or instead of the taxes mentioned in Item 1 of this Article. Competent authorities of Contracting states will notify each other on any essential changes made to their relevant tax laws.

3. Irrespective of any other provisions of this agreement no provision of this agreement affects the right of any political division or local government of the United Arab Emirates to apply the own laws and regulations concerning the taxation of the income and the capitals relating to ownership, management, production, investigation, operation, transportation and distribution of natural resources and hydrocarbons including oil and gas, and also their condensates, derivative and primary by-products. In case of discrepancy between this Item and any other provision of this agreement this Item will prevail.

Article 2

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

a) the terms "Contracting State" and "other Contracting state" mean the Russian Federation or the United Arab Emirates depending on context;

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