THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE STATE OF ISRAEL

of April 25, 1994

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

Government of the Russian Federation and Government of the State of Israel,

being guided by the aspiration to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and for the purpose of development of international trade and investment,

agreed as follows:

Article 1 of Person to which the Convention is applied

This Convention is applied to persons who are persons with the permanent residence in one or in both Contracting States.

Article 2 Taxes to which the Convention extends

1. This Convention is applied to taxes on the income, the collectable Contracting State, its political and administrative divisions or regional authorities, irrespective of method of their collection.

2. All taxes levied from the total amount or 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 companies and also the property increment value duties are considered as taxes on the income.

3. The existing taxes to which this agreement extends, in particular, are:

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

(i) "About the income tax of the companies and organizations",

(ii) "About the taxation of the income of banks",

(iii) "About the taxation of the income from insurance activity" and

(iv) "About the income tax from physical persons"

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

b) in relation to Israel

(i) income tax,

(ii) tax on the companies and

(iii) tax on the income from property acquisition

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

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