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

of December 5, 1998

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

The government of the Russian Federation and the Government of the Republic of Cyprus, wishing to sign the Agreement on avoidance of double taxation 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 each Contracting State or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of 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 levied from the total amount of the salary paid by the company and also taxes on the income from capital gain are considered as taxes on the income and the capital.

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

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

(iv) property tax of physical persons

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

b) in relation to Cyprus:

(i) income tax,

(ii) the corporate tax on the income,

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