AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE REPUBLIC OF INDIA

of March 25, 1997

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of the Republic of India, wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and aiming to encourage 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 levied in each Contracting State.

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

a) in relation to the Russian Federation:

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

(ii) the income tax from physical persons

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

b) in relation to India:

the income tax, including any allowance levied in addition to the income tax

(further the referred to as "Indian tax").

3. This agreement is applied also to any to similar or in essence to similar taxes on the income, collectable any Contracting State after signature date of this agreement in amendment or instead of the taxes mentioned in Item 2. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws.

Article 3. General determinations

1. In this agreement if other does not follow from context:

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