AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF NEW ZEALAND

of September 5, 2000

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 New Zealand,

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 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. The existing taxes to which this agreement extends are:

a) in New Zealand:

income tax

(in this agreement referred to as as "the New Zealand tax");

b) in Russia:

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

(ii) the income tax from physical persons

(in this agreement referred to as as "the Russian tax").

2. This agreement is applied also to any identical or in essence to similar taxes which are levied in addition to the existing taxes or instead of them after signature date of this agreement. Competent authorities of Contracting States will notify each other on any essential changes in tax legislations of the respective Contracting States.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

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