The convention between the Government of the Russian Federation and the Government of the Kingdom of Thailand

of September 23, 1999

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

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 the Contracting State irrespective of method of their collection.

2. All taxes levied from total income or from separate elements of the income including taxes on the income from alienation of personal or real estate, taxes on the total amount of the salary paid by the companies and also capital gain taxes are considered as taxes on the income.

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

a) in relation to Russia - taxes on the income and the profit levied according to the following Laws:

- "About the income tax of the companies and organizations"; and

- "About the income tax from physical persons"

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

b) in relation to Thailand:

- income tax;

- oil income tax

(further the referred to as "Thai taxes").

4. The 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. Competent authorities of Contracting States will notify each other on the considerable changes made to their relevant tax laws.

Article 3 General determinations

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

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