AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE ARAB REPUBLIC OF EGYPT

of September 23, 1997

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

The government of the Russian Federation and the Government of the Arab Republic of Egypt, wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital and for the purpose of encouragement of economic cooperation between two countries, 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 the capital levied on behalf of the Contracting State or its political division or regional authority irrespective of collection method.

2. All taxes levied from total of income, the total amount 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, and also taxes on the income from increase in capital value are considered as taxes on the income and the capital.

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

a) in relation to 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 organizations;

(iv) property tax of physical persons

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

b) in relation to the Arab Republic of Egypt:

(i) tax on income gained from real estate (including the agricultural land tax, tax on buildings);

(ii) the unified income tax from physical persons;

(iii) tax on corporate profit;

(iv) charges on development of financial resources of the State;

(v) the additional taxes levied in the form of percent from the amount of the taxes mentioned above, or otherwise

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

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