AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF UKRAINE

of February 8, 1995

About avoidance of double taxation of the income and property and prevention of tax avoidances

Government of the Russian Federation and Government of Ukraine,

wishing to sign the Agreement on avoidance of double taxation of the income and property and prevention of tax avoidances

and confirming the aspiration to development and deepening of the mutual relations,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement extends to taxes on the income and property levied according to the legislation of the Contracting State irrespective of method of their collection.

2. All taxes levied from total of income and property value or on income elements, including taxes on the income from alienation of personal or real estate and taxes on the total amount of the salary and other remunerations paid by any person are considered as taxes on the income and on property.

3. The existing taxes to which this agreement extends are:

a) in the Russian Federation - 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";

(iii). "About the property tax of the companies" and

(iv). "About the property tax of physical persons"

(the hereinafter referred to as "Russian taxes");

b) in Ukraine:

(i). tax on the income of the companies and organizations and

(ii). the income tax from citizens

(the hereinafter referred to as "Ukrainian taxes").

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