The convention between the Government of the Russian Federation and the Government of the Republic of Botswana

of April 8, 2003

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

The government of the Russian Federation and the Government of the Republic of Botswana, wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, and also for the purpose of development of economic cooperation between two countries

agreed as follows:

Article 1 of Person to which the Convention is applied

This Convention is applied to persons who are residents of one or both Contracting States.

Article 2 Taxes to which the Convention extends

1. Taxes to which this Convention extends are:

a) in relation to Botswana:

the income tax, including the property increment value duty

(further referred to as "Botswanian tax");

b) in relation to the Russian Federation:

i) tax on the income (profit) of the companies and organizations;

ii) the income tax from physical persons

(further referred to as "the Russian tax").

2. Nothing in this Convention will limit the right of any of Contracting States to levy the company income tax, engaged in investigation or development of natural resources, at the rate different from effective rate of the income tax of the companies of other industries.

3. Irrespective of other provisions of this Convention when the Botswanian tax is paid or is subject to payment according to the special tax Agreements ratified according to the tax legislation of Botswana, this Convention will not be applied or will be applied in the limits set by such Agreements.

4. This Convention is applied also to any identical or in essence to similar taxes which are levied after signature date of this Convention in amendment or instead of the existing taxes mentioned in Item 1. Competent authorities of Contracting States will notify each other on the essential changes made to their relevant tax laws.

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