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AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE ISLAMIC REPUBLIC OF IRAN

of March 6, 1998

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

Government of the Russian Federation and Government of the Islamic Republic of Iran,

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 in each Contracting State irrespective of method of their collection.

2. As taxes on the income and the capital all taxes levied from the total amount of the income, total cost 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 paid by the company and also the taxes levied from the income from increase in capital value will be considered.

3. The existing taxes to which this agreement extends are, in particular:

a) in the Islamic Republic of Iran:

- income tax;

- property tax;

b) in the Russian Federation:

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

- the income tax from physical persons;

- property tax of the companies; and

- property tax of physical persons.

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied in addition to the existing taxes or instead of them after signature date of the Agreement. Competent authorities of Contracting States within reasonable period of time 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:

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