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

of December 20, 2010

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

Government of the Russian Federation and Government of the Republic of Latvia,

wishing to sign the Agreement on avoidance of double taxation and on prevention of tax avoidance concerning taxes on the income and the capital and for the purpose of strengthening 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 on the capital levied on behalf of the Contracting State, or its political divisions or municipal authorities irrespective of method of their collection.

2. All taxes levied from total of income, the general capital or from elements of the income or the capital including taxes on the income from alienation of personal or real estate, and also taxes on the income from capital gain are considered as taxes on the income and on the capital.

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

a) in relation to the Russian Federation:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations; and

(iv) property tax of physical persons;

b) in relation to the Republic of Latvia:

(i) corporate income tax;

(ii) the income tax from physical persons; and

(iii) non-personal tax.

4. This agreement is applied also to any to similar or in essence to similar taxes which will be levied from the income or from the capital after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on any essential changes made to their corresponding tax legislation.

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