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

of November 26, 1999

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

The government of the Russian Federation and the Government of the Republic Iceland, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance 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 of income or from separate elements of the income 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 is applied are, in particular:

(a) in Iceland:

(i) domestic income tax;

(ii) emergency domestic income tax;

(iii) municipal income tax; and

(iv) tax on the income of bank institutions

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

(b) in 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").

4. This Convention is applied also to any to similar or in essence to the similar taxes on the income 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 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:

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