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

of March 12, 1999

About avoidance of double taxation and prevention of tax avoidance on the income

The government of the Russian Federation and the Government of the Republic of Indonesia, wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance 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. This agreement is applied to the taxes on the income levied on behalf of one of Contracting States irrespective of method of their collection.

2. As taxes on the income all taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal or real estate will be considered.

3. Taxes to which this agreement extends are:

a) in relation to the Russian Federation:

(i) income tax of the companies and organizations;

(ii) the income tax from physical persons

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

b) in relation to the Republic of Indonesia:

the income tax levied according to Undang-undang Pajak Penghasilan of 1984 (The law No. 7 of 1983 with changes)

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

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

Article 3. General determinations

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

a) the terms "Contracting State" and "other Contracting State" mean the Russian Federation (Russia) or the Republic of Indonesia (Indonesia);

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