of September 7, 2017
About elimination of double taxation concerning taxes on the income and about prevention of avoidance and tax avoidance
When signing the Convention between the Government of the Russian Federation and the Government of Japan on elimination of double taxation concerning taxes on the income and about prevention of avoidance and tax avoidance (further referred to as "Convention") the undersigneds agreed that the following provisions constitute integral part of the Convention:
1. Concerning articles 10 and 13 of the Convention:
(a) It is understood that the term "investment fund" when using in item 4 of Article 10 and item 4 of article 13 of the Convention includes mutual investment funds of Russia.
(b) It is understood that the term "dividends" as it is determined in Item 7 of article 10 of the Convention, includes any payments on shares of mutual investment funds of Russia.
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Actions of Items 1 - 3 Protocols are suspended by the Russian Federation according to the Presidential decree the Russian Federation of August 8, 2023 No. 585