THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE KINGDOM OF SPAIN

of December 16, 1998

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

The government of the Russian Federation and the Government of the Kingdom of Spain, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital,

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 and the capital levied on behalf of the Contracting State or its political divisions or regional authorities irrespective of method of their collection.

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

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

a) in Spain:

(i) the income tax from physical persons;

(ii) corporate tax;

(iii) capital tax; and

(iv) the local taxes on the income and the capital (further referred to as "the Spanish tax");

b) in Russia:

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

(ii) the income tax from physical persons;

(iii) property tax of the companies; and

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