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

of May 22, 1992

About avoidance of double taxation of the income and property

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

being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both States,

and for the purpose of avoidance of double taxation of the income and property,

decided to sign this agreement and agreed as follows:

Article 1. Persons to whom the Agreement is applied

1. This agreement is applied to persons who are persons with the permanent residence in one or in both Contracting States.

2. For the purposes of this agreement the term "person with the permanent residence in one Contracting State" means any person or any education which, by the legislation of this State, is subject in it to the taxation on the basis of the residence, the permanent place of stay, place of registration as the legal entity or any other similar criterion.

If the income turns out complete partnership, the permanent residence is determined according to the permanent residence of person, taxable concerning such income.

3. If according to Item 2 provisions person which is not physical person is person with the permanent residence in both Contracting States, it is considered face with the permanent residence in that Contracting State in which its actual governing body is located.

4. If according to Item 2 provisions the physical person is person with the permanent residence in both Contracting States, its provision is determined as follows:

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