AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA

of October 13, 2014

About avoidance of double taxation and about prevention of evasion from the taxation concerning taxes on the income

Government of the Russian Federation and Government of People's Republic of China,

wishing to sign the Agreement on avoidance of double taxation and on prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the agreement extends

This agreement extends to persons who are residents of one or both Contracting States.

Article 2. Taxes to which the agreement extends

1. This agreement extends to taxes on the income levied on behalf of the Contracting State, its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income or separate elements of the income including taxes on the income from alienation of personal or real estate and taxes on the total amount of the salary paid by the companies are considered as taxes on the income.

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

a) in China:

i) income tax;

ii) tax on the income of the companies

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

b) in Russia:

i) income tax of the organizations;

ii) income tax

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

4. This agreement is applied also to any identical or in essence to similar taxes which are established after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes which are made to their tax laws.

Article 3. General determinations

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

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