THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF MALTA

of April 24, 2013

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

The government of the Russian Federation and the Government of Malta, wishing to sign the Convention 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 Convention extends

This Convention is applied to persons which are residents of one or both Contracting States.

Article 2. Taxes to which the Convention extends

1. This Convention is applied to the 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 Convention is applied are, in particular:

a) in relation to Malta:

tax on the income

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

b) in relation to Russia:

(i) income tax of the organizations;

(ii) income tax

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

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