THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE KINGDOM OF DENMARK

of February 8, 1996

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and property

Government of the Russian Federation and Government of the Kingdom of Denmark,

wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and property,

agreed as follows:

Article 1 of Person to which the Convention is applied

This Convention is applied to persons who are persons with the permanent residence in one or in both Contracting States.

Article 2 Taxes to which the Convention extends

1. This Convention is applied to the taxes on the income and property levied in each Contracting State irrespective of method of their collection.

2. All taxes levied from the total amount of the income, total amount of property or from separate elements of the income or property including taxes on the income from alienation of personal or real estate are considered as taxes on the income and property.

3. Taxes to which this Convention is applied, in particular, are:

a) in relation to the Russian Federation - the taxes levied according to the 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";

(iv) "About the property taxes of physical persons"

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

b) in relation to Denmark:

(i) the income tax paid to the State (indkomstskatten til staten);

(ii) municipal income tax (den kommunale indkosmstskat);

(iii) the income tax paid to acts (den amtskommunal indcomstskat);

(iv) specific income tax (den saerlige indkomstskat);

(v) church rate (kirkeskatten);

(vi) dividend tax (udbytteskatten);

(vii) tax on percent (renteskatten);

(viii) tax on the income from copyright and licenses (royaltyskatten);

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