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

of December 14, 2000

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

The government of the Russian Federation and the Government of the Republic of Cuba, for the purpose of avoidance of double taxation and prevention of tax avoidance on the income and the capital, 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 wages amount 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 Cuba:

(i) income tax;

(ii) the income tax from physical persons;

(iii) tax on ownership or acquisition of separate types of property

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

b) in relation to Russia:

(i) income tax (income) of the companies and organizations;

(ii) the income tax from physical persons;

(iii) property tax of the companies and organizations;

(iv) property tax of physical persons

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

4. This agreement is applied also to any to similar or in essence to similar taxes which will be imposed after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States without delay will notify each other on any essential changes in their relevant tax laws.

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