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The agreement between the Government of the Russian Federation and the Government of the Azerbaijan Republic on avoidance of double taxation concerning taxes on the income and property

of July 3, 1997

Government of the Russian Federation and Government of the Azerbaijan Republic,

wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and property,

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 and property levied in Contracting States irrespective of method of their collection.

2. All taxes levied from total of income, the total amount of property or from separate elements of the income or property including taxes on the income from alienation of personal or real estate, and also the property increment value duties are considered as taxes on the income and property.

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

a) in the Azerbaijan Republic:

(i) income tax and separate income types of legal entities;

(ii) the income tax from physical persons; and

(iii) property tax

(further the referred to as "taxes of Azerbaijan");

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) property tax of physical persons

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

4. This agreement is applied also to any identical or in essence to similar taxes which will be levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in their corresponding tax legislation.

Article 3 General determinations

1. For the purposes of this agreement if other does not follow from context:

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