AGREEMENT BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND GOVERNMENT OF SYRIAN ARAB REPUBLIC

of September 17, 2000

About avoidance of double taxation concerning taxes on the income

The government of the Russian Federation and the Government of the Syrian Arab Republic, wishing to sign the Agreement on avoidance of double 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. This agreement is applied to the taxes on the income levied on behalf of the Contracting State or its political divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal or real estate, and also capital gain taxes are considered as taxes on the income.

3. The existing taxes to which this agreement is applied, in particular, are:

a) in the Russian Federation:

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

(ii) the income tax from physical persons

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

b) in Syria:

(i) tax on income gained from business, industrial and non-commercial (liberal professions) activity;

(ii) the income tax on the salary and salary;

(iii) the income tax from nonresidents;

(iv) tax on income gained from use of personal estate; and

(v) the additional taxes levied now or in the future in the form of percent from above-mentioned taxes either in any other form or at any other rate

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

4. This agreement is applied also to any to similar or in essence to the similar taxes levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws.

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