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

of May 4, 1996

About avoidance of double taxation concerning taxes on the income

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

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 extends to the taxes on the income levied in the Contracting State irrespective of what name of authority they are levied or method of their collection.

2. All taxes levied from total of income or from separate elements of the income including the income from alienation of personal or real estate belong to taxes on the income.

3. The existing taxes to which this agreement is applied are the following taxes:

a) in Russia:

(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 Finland:

(i) national income taxes;

(ii) corporate income tax;

(iii) utility tax;

(iv) church rate;

(v) the tax on percent levied at source;

(vi) the tax on the income of nonresidents levied at source

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

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