AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF IRELAND

of April 29, 1994

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of Ireland, being guided by the aspiration to sign the Agreement on avoidance of double taxation concerning taxes on the income, agreed as follows.

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are persons with the permanent residence in one or in both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income levied according to the legislation of each of Contracting States irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from their separate elements including taxes on the income from alienation of personal or real estate belong to taxes on the income.

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

(a) in the Russian Federation - the income taxes and the income levied according to the laws of the Russian Federation on:

(i) profit of the companies and organizations and

(ii) income of physical persons

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

(b) in Ireland

(i) income tax;

(ii) tax on the income of corporations;

(iii) tax on the income from property increase in value

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

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