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

of May 29, 2000

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

The government of the Russian Federation and the Government of the Portuguese Republic, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance 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 on behalf of the Contracting State or its political or administrative divisions or regional authorities irrespective of method of their collection.

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

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

a) in relation to Portugal:

(i) the income tax from physical persons;

(ii) corporate income tax; and

(iii) local additional corporate income tax

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

b) in relation to 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").

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