AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE'S REPUBLIC OF CHINA

of January 18, 2016

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

Government of the Russian Federation and Government of Hong Kong Special Administrative Region of People's Republic of China,

wishing to sign the Agreement on avoidance of double taxation and 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 Parties.

Article 2. Taxes to which the Agreement extends

1. This agreement extends to taxes on the income levied on behalf of the Contracting Party, 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 are considered as taxes on the income.

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

a) in relation to Hong Kong Special Administrative Region:

(i) income tax;

(ii) wage tax;

(iii) property tax;

irrespective of their charge according to personal assessment (personal assessment);

b) in relation to Russia:

(i) income tax of the organizations;

(ii) income 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, and also to any other taxes which the Contracting Party can establish in the future according to Items 1 and 2 of this Article. Competent authorities of Contracting Parties will notify each other on any essential changes which are made to their tax laws.

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