PROTOCOL

of October 1, 2020

About introduction of amendments to the Convention between the Government of the Russian Federation and the Government of Malta on avoidance of double taxation and about prevention of evasion from the taxation concerning taxes on the income from April 24, 2013

Government of the Russian Federation and Government of Malta,

wishing to sign the Protocol on introduction of amendments to the Convention between the Government of the Russian Federation and the Government of Malta on avoidance of double taxation and about prevention of evasion from the taxation concerning taxes on the income from April 24, 2013 (further - "Convention"),

agreed as follows:

Article I

1. To state Items 2 and 3 of the article 10 "Dividends" of the Convention 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.

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

iii. person having the actual right to dividends is resident of other Contracting State, and such face is the Government of this Contracting State, either its political division, or regional authority; or

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