PROTOCOL

of September 8, 2020

About introduction of amendments to the Agreement between the Government of the Russian Federation and the Government of the Republic of Cyprus about avoidance of double taxation concerning taxes on the income and the capital of December 5, 1998

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

wishing to sign the Protocol on introduction of amendments to the Agreement between the Government of the Russian Federation and the Government of the Republic of Cyprus about avoidance of double taxation concerning taxes on the income and the capital signed on December 5, 1998 (further - "Agreement"),

agreed as follows:

Article I

1. Item 2 of the article 10 "Dividends" of the Agreement to state in the following edition:

"2. However such dividends can be also assessed with tax in that Contracting State which resident is the company paying dividends and according to the legislation of this Contracting State, but if person having the actual right to dividends is resident of other Contracting State, then the tax levied thus shall not exceed 15 percent from the total amount of dividends.".

2. Add the article 10 "Dividends" of the Agreement with new Item 3 following of content:

"3. Irrespective of provisions of Items 1 and 2 the dividends paid by the company which is resident of the Contracting State can be also assessed with tax in this Contracting State according to the legislation of this Contracting State, but if:

i. person having the actual right to dividends is resident of other Contracting State, and such face is insurance organization or the pension fund; or

ii. person having the actual right to dividends is resident of other Contracting State, and such face is the company which shares are quoted on the registered stock exchange provided that at least than 15 percent of shares granting voting power in such company are in free circulation and which directly owns at least than 15 percent of the capital of the company paying dividends during the period of 365 days including day of dividend payout; or

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