The agreement between the Government of the Russian Federation and the Government of Georgia on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and property

of August 4, 1999

The government of the Russian Federation and the Government of Georgia, being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both Contracting States, and for the purpose of avoidance of double taxation of the income and property decided to sign this agreement and agreed as follows:

Article 1 of Person to which the Agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States.

Article 2 Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income (profit) and property levied in Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income or the capital or on separate elements of the income or property, including the taxes on the income from alienation of personal or real estate levied from the total amount of the salary or salary paid by the companies and also taxes on property value addition are considered as taxes on the income (profit) and property.

3. Taxes to which this agreement is applied, in particular, are:

a) in Georgia:

(i) income tax (income) of the companies;

(ii) the income tax from physical persons;

(iii) property tax of the companies;

(IV) the property tax from physical persons (the hereinafter referred to as "taxes of Georgia")

b) in the Russian Federation:

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

(ii) the income tax from physical persons;

(iii) property tax of the companies; and

(IV) the property tax of physical persons (further the referred to as "taxes of the Russian Federation");

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