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

of March 31, 1998

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 Republic of Namibia, 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 in each Contracting State irrespective of method of their collection.

2. Taxes to which this Convention is applied are:

a) in Namibia: (i) income tax; (ii) tax on the shareholders who are nonresidents; and (iii) tax on the income from transactions with oil (further referred to as "Namibian tax");

b) in the Russian Federation: (i) income tax of the companies and organizations; (ii) the income tax from physical persons (further referred to as "the Russian tax").

3. This Convention is applied also to any to similar or in essence to the similar taxes levied after signature date of this Convention in amendment or instead of the taxes mentioned in Item 1. Competent authorities of Contracting States will notify each other on any 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) the term "Namibia" means the Republic of Namibia and when using in geographical sense includes the territorial sea, and also exclusive economic zone and the continental shelf, in that measure in which Namibia performs the sovereign rights according to its domestic legislation and rules of international law concerning investigation and operation of seabed, its subsoil and the waters which are over it;

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