THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE REPUBLIC OF FILLIPINA

of April 26, 1995

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 the Philippines, being guided by the aspiration to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, and also to develop and strengthen economic, scientific, technical and cultural cooperation between two States,

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

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

3. The existing taxes to which this Convention extends, in particular, are:

a) in case of the Russian Federation:

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

(ii) the income tax from physical persons

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

b) in case of Philippines:

the income tax levied according to part II (about the income tax) the National code of the internal income

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

4. This Convention will be applied also to similar taxes any other in essence which will be levied in amendment or instead of the taxes specified in Item 3.

Competent authorities of Contracting States will notify each other on essential changes in their relevant tax laws.

Article 3 General determinations

1. For the purposes of this Convention if other does not follow from context:

a)

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