of September 4, 1997
About avoidance of double taxation concerning taxes on the income and property
Government of the Russian Federation and Government of the Kingdom of Morocco,
wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and property,
agreed as follows:
This agreement is applied to persons who are residents of one or both Contracting States.
1. This agreement extends to taxes on the income and property levied on behalf of each Contracting State irrespective of method of their collection.
2. All taxes levied from total of income, total cost of property or on separate elements of the income or property, including taxes on the income from alienation of personal or real estate, and also the property increment value duties are considered as taxes on the income and on property.
3. The operating taxes to which this agreement is applied, in particular, are:
a) concerning Morocco:
(i) tax on the companies;
(ii) general tax on the income, including tax on the professional and land income exempted from general tax on the income;
(iii) the stockholder's tax or shares and the income equated to them;
(iv) tax on the income from real estate;
(v) fee in fund of national solidarity;
(vi) tax on the fixed income from sales of products; and
(vii) the income tax from alienation of shares and shares;
(further referred to as "the Moroccan tax");
b) concerning Russia - the taxes levied according to the following Laws:
(i) "About the income tax of the companies and organizations";
(ii) "About the income tax from physical persons";
(iii) "About the property tax of the companies";
(iv) "About the property tax of physical persons";
(further referred to as "the Russian tax").
4. The agreement is applied also to any to similar or in essence to similar taxes which will be established after signature date of the Agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on the essential changes made to their corresponding tax legislation.
1. For the purposes of this agreement if other does not follow from context:
a) the terms "one Contracting State" and "other Contracting State" mean, depending on context, Russia or Morocco;
b) Morocco means the territory of the Kingdom of Morocco, and also its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law;
c) Russia means the territory of the Russian Federation, and also its exclusive economic zone and the continental shelf determined according to the Convention of the UN on maritime law;
d) the term "person" includes physical persons, the companies, the companies and any other associations of persons;
e) the term "company" means any legal entity or any education which for the purposes of the taxation is considered as the legal entity;
f) the term "national persons" means any physical person which has nationality of one Contracting State according to the current legislation of this State;
g) the term means "competent authority":
(i) in relation to Morocco - the Minister of Finance or his representative it the representative;
(ii) in relation to Russia - the Ministry of Finance of the Russian Federation or the representative authorized by it;
h) expression "international delivery" means any transportation sea or the aircraft operated by the company which place of registration and the place of effective management are in the Contracting State, except cases when sea or the aircraft is operated only between the Items located in other Contracting State;
(i) the term "tax" means, according to context, the Moroccan tax or the Russian tax.
2. In case of application of this agreement by the Contracting State any term or expression which in it are not determined make sense which is given them by the legislation of this State if other does not follow from context. In case of discrepancy between the legislation of this State concerning taxes to which the Agreement extends and other areas of the legislation of this State the legislation concerning taxes to which the Agreement extends will be applied.
1. For the purposes of this agreement the term "resident of the Contracting State" means any person who by the legislation of this State is subject to the taxation in this State based on its residence, the permanent residence, its place of registration, its place of effective management or any other criterion of similar nature. However this term does not include faces, taxable only in this State concerning the income from the sources which are in this State or concerning the property which is in it.
2. In case according to Item 1 provisions the physical person is resident of both Contracting States, its provision is determined as follows:
a) it is considered resident of that Contracting State in which it has permanent housing; if it has permanent housing in both Contracting States, it is considered resident of that Contracting State in which it has the most close personal and commercial relations (the center of vital interests);
b) if the Contracting State in which this person has the center of vital interests cannot be determined or if it has no permanent housing in one of Contracting States, it is considered resident of that State where it usually stays;
c) if it usually stays in both Contracting States or if it usually does not stay in one of them, it is considered resident of that State which nationality it has;
d) if both Contracting states consider this person as the citizen or if it is not citizen of any of them, then competent authorities of Contracting States resolve this issue by mutual consent.
3. In case according to Item provisions 1 person, other than physical person, is resident of both Contracting States, it is considered resident of the State in which there is place of its effective management.
1. For the purposes of this agreement the term "permanent mission" means the permanent place of activities through which the company of one Contracting State fully or partially performs the activities in other Contracting State.
2. The term, in particular, includes "permanent mission":
a) management place;
b) department;
c) office;
d) factory;
e) workshop and
f) mine, oil or gas well, pit or any other place of production of natural resources.
3. The building site or mounting object form permanent mission only if duration of such works is equal or exceeds 8 months.
4. Irrespective of the previous provisions of this Article it is considered that the permanent mission is not formed in case:
a) uses of constructions only for the purposes of storage or goods demonstration belonging to the company;
b) contents of the goods belonging to the company only for the purposes of storage or demonstration;
c) contents of the goods belonging to the company only for the purposes of conversion by other company;
d) contents of the permanent place of activities only for the purpose of purchase of goods or for information collection for the company;
e) contents of the permanent place of activities only for the purpose of implementation for the company of any other activities of preparatory or auxiliary nature;
f) contents of the permanent place of activities only for implementation of any combination of the types of activity mentioned in subitems from a) to e).
5. Person acting in the Contracting State on behalf of the company of other Contracting State (other, than the agent using the independent status noted further in Item 6) is considered as "permanent mission" in the first State:
a) if in this State it has general powers which it in it usually has, allowing it to conduct negotiations and to sign contracts for the company or on behalf of the company; or
b) if it usually has in the first State warehouse of goods in which it regularly takes goods for the purpose of delivery for the company.
6. The company will not be considered as the having permanent mission in the Contracting State only because it performs the activities through the broker, the general broker or any other agent with the independent status provided that these persons act within the regular activities.
7. The fact that the company which is resident of one Contracting State controls or is controlled by the company which is resident of other Contracting State or which performs the activities there (or through permanent mission, or any otherwise) in itself does not turn one of these companies into permanent mission another.
1. Income gained by resident of one Contracting State from the real estate (including the income from rural and forestry) which is in other Contracting State is assessed with taxes in this other State.
2. The term "real estate" has significance which is attached to it by the legislation of the Contracting State in which there is this property. This term anyway includes property, auxiliary in relation to real estate, the cattle and the equipment used in rural and forestry, is right to which provisions of private law are applied to land property, the right known as usufruct of real estate, and is right on variables or fixed payments as compensation for development or the right to development of mineral inventories, sources and other natural resources; sea, river and aircrafts are not considered as real estate.
3. Provisions of Item 1 are applied to income gained from direct use, letting or in lease or uses in any other form of real estate.
4. Provisions of Items 1 and 3 are applied also to the income from real estate of the company and to the income from the real estate used for implementation of independent personal services.
1. The profit of the company of one Contracting State is assessed with tax only in this State if only the company does not perform the activities in other Contracting State through the permanent mission which is there. If the company performs the activities thus, then the profit of the company is assessed with tax in other State, but only in that part which belongs to this permanent mission.
2. Taking into account Item provisions 3, in case the company of one Contracting State performs the activities in other Contracting State through the permanent mission located there, then in each Contracting State the profit which it could receive if it was the isolated and separate company occupied with the same or similar activities under the same or similar conditions belongs to this permanent mission and was effective in complete independence of the company which permanent mission it is.
3. In case of determination of profit of permanent mission deductions of the expenses incurred for the purposes of this permanent mission including management and total administrative expenses which would be subtracted if the permanent mission is the independent company, in the amount of in which they are reasonably attributed to permanent mission shall be made irrespective of whether these expenses in the Contracting State where there is permanent mission or beyond its limits are incurred.
4. If in the Contracting State it is accepted to determine the taxable profit relating to permanent mission on the basis of pro rata distribution of total amount of profit of the company between its separate divisions, nothing in Item 2 of this agreement prevents this Contracting State to determine taxable profit by means of such distribution; the chosen method of distribution shall yield the results answering the main objective pursued by this agreement.
5. For the purposes of the previous Items the profit relating to permanent mission will be determined by annually same method if only there is no good and sufficient reason for its change.
6. In case the profit includes income types about which it is told separately in other Articles of this agreement, situations of these Articles are not affected by provisions of this Article.
1. The profit got from use on maritime international transports and aircrafts is assessed with tax only in the Contracting State in which there are place of registration and the place of effective management of the company.
2. If the place of effective management of shipping company is onboard the ocean ship, then it is considered that it is located in that Contracting State in which there is port of documentation of the ocean ship, or in absence of port of documentation, in the Contracting State which resident is the owner of the ocean ship.
3. Provisions of Item 1 are applied also to the income from participation in bullet, joint business or international organization of vehicles.
In case
a) the company of the Contracting State directly or indirectly participates in management, control or the capital of the company of other Contracting State, or
b) the same persons directly or indirectly participate in management, control or the capital of the company of one Contracting State and the company of other Contracting State,
in either case between two companies in their commercial and financial relations conditions, other than those which would take place between two independent companies, then any profit which without these conditions could be added to one of the companies are created or established, but because of availability of these conditions to it it was not added, it can be included in profit of this company and, respectively, it is taxed.
1. The dividends paid by the company which is resident of one Contracting State to resident of other Contracting State can be assessed with taxes in this other State.
2. However such dividends can be also assessed with tax in that Contracting State which resident is the company paying dividends and according to the legislation of this State. However, if person receiving dividends has the actual right to them, the collectable tax shall not exceed:
a) 5 percent from the total amount of dividends if participation of resident of other Contracting State in the capital of this company exceeds 500000 American dollars;
b) 10 percent from the total amount of dividends in other cases.
3. The term "dividends" when using in this Article means the income from shares, constituent shares or the similar constituent rights, except for debt requirements, and also the income - even in the form of percent - on which the same tax regime, as well as extends to the income from shares, according to the legislation of that State which resident is the company paying dividends.
4. Provisions of Items 1 and 2 are not applied if person who actually have the right to dividends, being resident of the Contracting State, performs industrial or trading activity in other Contracting State which resident is the company paying dividends through the permanent mission located there or renders in this other State independent personal services from the permanent base which is there, and participation concerning which dividends are paid is really connected with such permanent mission or permanent base. Provisions of Article 7 or Article 14, depending on circumstances are in that case applied.
5. In case the company which is resident of the Contracting State gets profit or the income in other Contracting State, this other State can not tax the dividends paid by this company except cases when such dividends are paid to resident of this other State or if participation concerning which dividends are paid is really connected with the permanent mission or permanent base which are in this other State and also not to subject to the taxation retained earnings of the company even if the paid dividends or retained earnings consist fully or partially of the profit or the income arising in this other State.
1. The percent arising in one Contracting State and paid to resident of other Contracting State are assessed with taxes in this other State.
2. However such percent - except for percent on the loans allowed one of Contracting States or guaranteed by the State, and percent on currency deposit deposits - are also assessed with tax in that Contracting State in which they arise also according to the legislation of this State; but if person receiving these percent has the actual right to them, the tax established thus cannot exceed 10 percent of total amount of percent.
3. The term "percent" when using in this Article means the income from debt requirements of any kind, regardless of mortgage providing and regardless of ownership of the participation right in profits of the debtor, and in particular, the income from Government securities and on bonds of loans, including premiums and prizes to these securities. However this term does not include, in sense of this Article, penalties for untimely payments, and also the percent considered as dividends based on the first phrase of Item 3 of Article 10.
4. Provisions of Items 1 and 2 are not applied if person having the actual right to percent, being resident of one Contracting State, performs industrial or trading activity in other Contracting State in which there are percent, through the permanent mission which is there, or renders in this other State independent personal services from the permanent base which is there, the debt requirement based on which interests are paid, really belongs to such permanent mission or permanent base. Provisions of Article 7 or Article 14, depending on circumstances are in that case applied.
5. It is considered that percent arise in the Contracting State if payer is the public authority created in this State or resident of this State. However if person paying interests irrespective of, it is resident of the Contracting State or not, has in the Contracting State permanent mission or permanent base in connection with which there was debt on which interests are paid, and expenses on payment of these percent are incurred by such permanent mission or permanent base, then it is considered that such percent arise in the State in which there is permanent mission or permanent base.
6. If because of the special relations between the payer and person having the actual right to percent or between both of them and any third party, the amount of percent relating to the debt requirement based on which it is paid exceeds the amount which would be approved between the payer and person having the actual right to percent in the absence of such relations, provisions of this Article are applied only to the last mentioned amount. In that case excessive part of payment is still assessed with tax according to the legislation in the Contracting State where there are percent.
1. The income from copyright and licenses arising in one Contracting State and paid to resident of other Contracting State is assessed with tax in this other State.
2. However such income from copyright and licenses is also assessed with tax in that Contracting State in which they arise also according to the legislation of this State, but if person gaining income from copyright and licenses has the actual right to them, the tax established thus shall not exceed 10 percent of total amount of the income from copyright and licenses.
3. The term "income from copyright and licenses" when using in this Article means the remunerations of any kind paid for use or for provision of right to use of copyright of the literary work, arts or sciences including cinema movies, and the movies or records used for radio - and television broadcasting, any computer program, any patent, factory or trademark, design or model, the plan, confidential formula or process as well as for use or provision of right to use of industrial, commercial or scientific equipment and remuneration for technical assistance.
4. Provisions of Items 1 and 2 are not applied if person having the actual right to the income from copyright and licenses, being resident of one Contracting State, performs industrial or trading activity in other Contracting State in which there is income from copyright and licenses, through the permanent mission located there or renders independent services in this other State from the permanent base which is there, and the right or property concerning which the income from copyright and licenses is paid are really connected with such permanent mission or permanent base. Provisions of Article 7 or Article 14, depending on circumstances are in that case applied.
5. It is considered that the income from copyright and licenses arises in the Contracting State if payer is the authority created in this State or resident of this State. However if person paying the income from copyright and licenses irrespective of is it resident of the Contracting State or not, has in this Contracting State permanent mission or permanent base in connection with which there was obligation to pay the income from copyright and licenses, then it is considered that such income from copyright and licenses arises in that State in which the permanent mission or permanent base is located.
6. If because of the special relations between the payer and person having the actual right to the income from copyright and licenses or between both of them and any third party the amount of the income from copyright and licenses taking into account use, right to use or information for which they are paid exceeds the amount which would be approved between the payer and person having the actual right to this income in the absence of such relations, provisions of this Article are applied only to the last mentioned amount. In that case excessive part of payment is still subject to the taxation according to the legislation of that Contracting State where there is income from copyright and licenses.
1. Income gained by resident of one Contracting State from the alienation of the real estate determined in Article 6 and which is in other Contracting State can be assessed with taxes in this other State.
2. The income from alienation of the personal estate constituting part of commercial property of permanent mission which the company of one Contracting State has in other Contracting State or from the personal estate relating to permanent base which is at the disposal of resident of one Contracting State in other Contracting State for the purposes of rendering independent personal services including such income from alienation of such permanent mission (separately or in total with the whole company) or such permanent base, is assessed with tax in this other State.
3. Income gained from alienation sea and the aircrafts used in international carriages or the personal estate connected with operation of these vehicles is subject to the taxation only in that Contracting State in which there is place of registration and the place of effective management of the company.
4. The income from alienation of shares of the company which property mainly consists of the real estate which is in the territory of the Contracting State is assessed with tax in this State.
5. The income from alienation of any other property which is not specified in Items 1, 2 and 3, is assessed with taxes only in that Contracting State which resident is person alienating property.
1. Income gained by resident of one Contracting State for professional services or other activities of independent nature it is assessed with tax only in this State, except as specified, when this resident has in other Contracting State permanent base for the purposes of implementation of such activities.
If it has such permanent base, the income is assessed with taxes in other State, but only in that part which belongs to this permanent base.
2. The term "professional services" includes, in particular, independent scientific, literary, artistic, educational or teaching activities as well as independent activities of doctors, lawyers, engineers, architects, dentists and accountants.
1. Taking into account provisions of Articles 16, the 18 and 19 salary, salary and other similar rewards earned by resident of one Contracting State concerning work for hire are assessed with tax only in this State if only work for hire is not carried out in other Contracting State. If work for hire is carried out thus, the received with respect thereto remuneration can be assessed with tax in this other State.
2. Irrespective of Item provisions 1, the reward earned by resident of one Contracting State concerning the work for hire which is carried out in other Contracting State is assessed with tax only in the first mentioned State if:
a) the receiver is in other State during the period or the periods which are not exceeding in total 183 days in the considered calendar year and
b) remuneration is paid by the employer or on behalf of the employer who is not resident of other State, and
c) expenses on payment of remuneration are not incurred by permanent mission or permanent base which the employer has in other State.
3. Irrespective of the previous provisions of this Article, the reward earned concerning the work for hire which is carried out onboard sea or the aircraft operated in international carriages is assessed with tax only in that Contracting State in which there are place of registration and the place of effective management of the company.
Remunerations, others than about what it is told in Article 15 of this agreement, received by resident of one Contracting State as the member of the administrative or supervisory board or the company which is resident of other Contracting State are assessed with taxes in this other State.
1. Irrespective of provisions of Articles 14 and 15, income gained by resident of one Contracting State from the personal activities performed in other Contracting State as the worker of arts, such as the actor of theater, cinema, radio or television or the musician or as the athlete, is assessed with taxes in this other State.
2. If the income from the personal activities performed by the worker of arts or the athlete in this quality is charged not to the worker of arts or the athlete, and other person, this income, irrespective of provisions of Articles 7, 14 and 15, is assessed with taxes in that Contracting State in which activities of the worker of arts or the athlete are performed.
1. a) The pensions and other similar remunerations paid from the public funds formed in the Contracting State are assessed with taxes only in this State.
b) However the pensions received by physical person concerning the services rendered in one Contracting State are assessed with taxes only in other Contracting State if this person is resident of this other State and has nationality of this State.
2. The pensions and other similar payments paid to resident of the Contracting State concerning the service rendered in the past, from funds, others what specified in Item 1, are assessed with taxes only in this State.
1. a) Remunerations, others than the pensions paid by the Contracting State, to physical person for the service performed for this State it is assessed with tax only in this State.
b) However these remunerations are assessed with tax only in other Contracting State if the service is performed in this State and if physical person, being resident of this State:
(i) is citizen of this State; or
(ii) not resident of this State it became exclusive for the purpose of implementation of service.
2. Provisions of Articles 15 and 16 are applied to the remunerations paid concerning the service performed within the industrial or business activity performed by the state bodies of the power created in the Contracting State.
1. The amounts which the student or the probationer who is or just before arrival to the Contracting State being resident of other Contracting State and which is in the first mentioned State only for the purpose of education or practical training, gets for the purposes of the content, educations and practical training, are not assessed with tax in this first mentioned State provided that such payments arise from sources outside this State.
2. Concerning grants and remunerations for work for hire to which the Item 1, the student or the probationer is not applied for the purpose of Item 1, will have, however, during training or practical training the same rights to tax exemption or to their decrease as residents of the State in which it stays.
1. Elements of the income of resident of the Contracting State irrespective of where they arise, not mentioned in the previous Articles of this agreement, are subject to the taxation only in this State.
2. Provisions of Item 1 are not applied to the income, others, than the income from the real estate determined in Item 2 of Article 6, if the receiver of such income, being resident of one Contracting State, performs industrial or trading activity in other Contracting State through the permanent mission located in it or renders in this other State independent individual services from the permanent base which is there, and the right or property concerning which income is gained are actually connected with such permanent mission or permanent base. Provisions of Article 7 or Article 14, depending on circumstances are in that case applied.
3. Irrespective of provisions of Items 1 and 2, elements of the income of resident of one Contracting State which arise in other Contracting State, and about which it is not told in the previous Articles of this agreement, are also assessed with tax in this other State.
1. The property provided by real estate, specified in Article 6, which is owned by the resident of one Contracting State and which is in other Contracting State is assessed with tax in this other State.
2. The property provided by the personal estate constituting part of assets of permanent mission which the company of one Contracting State has in other Contracting State or the personal estate relating to the permanent base used by resident of one Contracting State in other Contracting State for the purpose of rendering independent personal services is assessed with tax in this other State.
3. The property provided sea or the aircrafts operated in international carriages, the river crafts used in domestic transports, and also the personal estate connected with operation of such ocean, air or river crafts is subject to the taxation only in that Contracting State in which there are place of registration and the place of effective management of the company.
4. All other elements of property of resident of the Contracting State are assessed with tax only in this State.
1. If the resident of one Contracting State gains income, others than about what it is told in Item 2, which, according to provisions of this agreement, are assessed with taxes in other Contracting State, the first mentioned State exempts these tax revenues, but it can apply to calculation of the amount of these taxes on remaining balance of the income of this resident the same rate as though the income about which there is a speech would not be tax-exempt.
2. If the resident of one Contracting State gains income mentioned in Articles 10, 11 and 12, or owns property which, according to provisions of this agreement, is assessed with taxes in other Contracting State, the first mentioned State accepts deduction from the tax levied from the income or property of this resident, the amount equal to tax on the income and/or the property tax paid in other Contracting State. This deduction, however, cannot exceed parts of tax on the income or the property tax levied according to the legislation of the first mentioned State.
1. Citizens of one Contracting State are not exposed in other Contracting State to other or more burdensome taxation or the related obligation, than the taxation or the obligation to which citizens of this other State who are in the same conditions, in particular concerning residence are exposed or can be exposed. This provision is applied also, irrespective of Article provisions 1, to persons who are not residents of one Contracting State or both Contracting States.
2. Provisions of Item 1 cannot be interpreted as the individual deductions obliging one Contracting State to provide to residents of other Contracting State, privileges and discounts on taxes depending on their marital status or availability of dependents which it provides to the residents.
3. The taxation of the company of the Contracting State shall not be in other Contracting State irrespective of whether has this company permanent mission or not, less favorable there, than the taxation of the companies of this other State performing similar activities.
4. Except as specified, when Article provisions 9, of Item 5 of Article 11 or Item 5 of Article 12, percent, the income from copyright and licenses and other payments made by the company of one Contracting State to resident of other Contracting State are applied shall be deductible for the purposes of taxable profit determination of such company on the same conditions as though they were paid to resident of the first mentioned State. Similar to any debts of the company of one Contracting State to resident of other Contracting State debts to resident of the first mentioned State shall be deductible for the purposes of determination of taxable property of such company on the same conditions, as.
5. The companies of one Contracting State which capital fully or partially, directly or indirectly belongs or is controlled by one or several residents of other Contracting State, the taxation and the related obligations to which other similar companies of this first mentioned State are exposed or can be exposed are not exposed in the first mentioned State to any taxation or the related obligation to other or more burdensome, than.
6. Provisions of this agreement shall not be obstacle for application of the provisions concerning the taxation stipulated by the legislation one of the Contracting States promoting investment attraction.
1. If person considers that actions of one Contracting State or both Contracting States bring or will lead to its taxation not according to provisions of this agreement, it can, irrespective of the remedies provided by the domestic legislation of these States to submit the application to competent authority of that Contracting State in which it is resident, or if its case falls under Item 1 of Article 24, to competent authority of that Contracting State which citizen it is. The application shall be submitted within three years from the moment of the first notification on the actions leading to the taxation not according to Agreement provisions.
2. The competent authority will aim if it considers the statement reasonable and if he is not able to come to the satisfactory decision, to resolve issue by mutual consent with competent authority of other Contracting State for the purpose of avoidance of the taxation which is not corresponding to Agreement provisions.
3. Competent authorities of Contracting States will aim to resolve any difficulties or doubts arising in case of interpretation or application of the Agreement by mutual consent.
4. Competent authorities of Contracting States hold mutual consultations concerning the administrative measures necessary for accomplishment of provisions of this agreement, and in particular concerning the reasons represented by residents of each Contracting State for application in other State of tax exemption or decrease in the taxes provided by this agreement.
5. Competent authorities of Contracting States can also come into direct contacts with each other for the purposes of achievement of consent as it is specified in the previous Items. If exchange of opinions in oral form allows to reach consent, this exchange is carried out within the Commission including representatives of competent authorities of Contracting States.
1. Competent authorities of Contracting States communicate, necessary for accomplishment of provisions of this agreement or the national legal system of the Contracting States concerning taxes to which the Agreement in that measure when the taxation provided by these legislations does not contradict the Agreement extends. Exchange of information is not limited to Article 1. Any information obtained by the Contracting State is considered confidential also as well as information obtained by the national legal system of this State and is told only persons or bodies (including courts and administrative authorities) occupied with assessment or collection of taxes, specified in the Agreement, recovery by enforcement or legal prosecution concerning taxes or pronouncement of decisions in claims concerning these taxes. Such persons or bodies use information only for these purposes. They can open this information during proceeding in open court or in case of adoption of judgments.
2. In any case of provision of Item 1 will not be interpreted as imposing the obligation on one of Contracting States:
a) hold the administrative events contradicting the laws and administrative practice of this or other Contracting State;
b) provide information which cannot be received on the basis or during customary administrative practice of this or other Contracting State;
c) provide information which would open any trade, industrial or professional secrecy or trade process, or information which disclosure would contradict its interests.
Provisions of this agreement do not mention the fiscal privileges of employees of the diplomatic missions and consular establishments provided by general rules of international law or according to provisions of special agreements.
Provisions of this agreement cannot be interpreted as the breaking provisions of tax procedure containing in all agreements on condition of their ratification.
1. Contracting states in writing through diplomatic channels will notify each other on performing procedures, necessary for entry into force of this agreement.
2. The agreement becomes effective from the date of receipt of the last of the notifications provided in Item 1 of this Article, and its provisions will be applied:
a) to the taxes levied at source - from the income added or paid since January first of the year following after year of its entry into force;
b) to other established taxes on the income for the taxable periods beginning since the January first years following after year of its entry into force;
c) to the established taxes on property elements existing for January first of any year following after year of its entry into force.
This agreement remains in force until one of Contracting States does not stop its action. Each Contracting State can terminate the Agreement by transfer through diplomatic channels of the written notice of cancellation at least in six months prior to the termination of any calendar year after five years from the effective date of the Agreement.
In that case the Agreement stops the action:
a) concerning the taxes levied at source - from the income added or paid since January first of the year following after year of cancellation;
b) concerning other established taxes on the income, for the taxable periods beginning since the January first years following after year of cancellation;
c) concerning the established taxes, on elements of property, existing for January first of the year following after year of cancellation.
In witness whereof, the undersigneds, properly on that representatives, signed this agreement.
It is made in Moscow on September 4, 1997, in the Russian, Arab and French languages, all texts are equally authoritative. In case of discrepancy in interpretation between the Russian and Arab texts, the text in French is taken into account.
|
For the Government Russian Federation (signature) |
For the Government Kingdoms of Morocco (signature) |
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The law of the Russian Federation of 27.12.1991 No. 2116-1 "About the income tax of the companies and organizations" ceased to be valid since January 1, 2002 in connection with adoption of the Federal Law of the Russian Federation of 06.08.2001 No. 110-FZ, except separate provisions which void in special procedure.
Since January 1, 2002 the questions concerning collection of the income tax of the organizations are regulated by Chapter 25 of the Tax Code of the Russian Federation.