AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF AUSTRALIA

of September 7, 2000

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 Australia,

wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

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

Article 2. Taxes to which the Agreement extends

1. The existing taxes to which this agreement extends are:

(a) in Australia:

the income tax and rent tax on the resources concerning the offshore projects connected with investigation or development of oil resources levied according to the federal legislation of Australia;

(b) in Russia:

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

(ii) the income tax from physical persons.

2. This agreement is applied also to any identical or in essence to similar taxes which are levied according to the federal legislation of Russia or the federal legislation of Australia in addition to the existing taxes or instead of them after signature date of this agreement.

Article 3. General determinations

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

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