AGREEMENT BETWEEN THE RUSSIAN FEDERATION AND FEDERAL REPUBLIC OF GERMANY

of May 29, 1996

About avoidance of double taxation concerning taxes on the income and property

Russian Federation and Federal Republic of Germany,

being guided by desire to sign the Agreement on avoidance of double taxation concerning taxes on the income and property,

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. This agreement is applied to the taxes on the income and property which are subject to payment according to the tax legislation of each of Contracting States irrespective of method of their collection.

2. The taxes established on comprehensive income, cumulative property or on part of the income or property including taxes on the income from alienation of personal or real estate are considered as taxes on the income and property.

3. In particular, treat the taxes operating now to which action of this agreement extends:

a) in the Russian Federation:

income tax of the companies and organizations;

the income tax from physical persons;

property tax of the companies and property tax of physical

persons,

further the referred to as "Russian taxes";

b) in the Federal Republic of Germany:

income tax;

tax on corporations;

property tax;

the tax of trade and the tax allowance in support of solidarity,

further the referred to as "German taxes".

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