The convention between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela

of December 22, 2003

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

The government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela, wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation 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 established in each of Contracting States according to the legislation 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, taxes on the total amount of the salary paid by the companies 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 extends are, in particular:

a) in relation to Venezuela:

tax on the income and assets

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

b) in relation to the Russian Federation:

(i) income tax of the organizations;

(ii) the income tax from physical persons;

(iii) property tax of the organizations;

(iv) property tax of physical persons

(further referred to as "the Russian tax").

4. This Convention is applied also to any identical or in essence to similar taxes which are levied after signature date of this Convention in amendment or instead of the existing taxes. At the end of every year competent authorities of Contracting States will notify each other on the corresponding changes made to their relevant tax laws.

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