For The Government Of The Republic Of Latvia And The Government Of The Russian Federation Treaty On Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income And Capital And Its Protocol

Original Language Title: Par Latvijas Republikas valdības un Krievijas Federācijas valdības līgumu par nodokļu dubultās uzlikšanas un nodokļu nemaksāšanas novēršanu attiecībā uz ienākuma un kapitāla nodokļiem un tā Protokolu

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Read the untranslated law here: https://www.vestnesis.lv/ta/id/232250

The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Government of the Russian Federation Treaty on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital and of the Protocol article 1. 2010 December 20, Moscow signed by the Government of the Republic of Latvia and the Government of the Russian Federation Treaty on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter the agreement) and the Protocol to this law is adopted and approved.
2. article. The Treaty and its Protocol commitments provided for in the coordinated by the Ministry of finance.
3. article. The agreement and the Protocol shall enter into force on article 30 of the Treaty and laid down in the order, and the Ministry of Foreign Affairs shall notify the newspaper "journal".
4. article. The law shall enter into force on the day following its promulgation. With the law put a contract and its Protocol Latvian and English.
The Saeima adopted the law on 9 June 2011.
President Valdis Zatlers in Riga in 2011 g. June 29, the Government of the Republic of Latvia and the Government of the Russian Federation Treaty on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital the Government of the Republic of Latvia and the Government of the Russian Federation, reaffirming willingness to conclude an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, as well as to promote the economic cooperation between the two countries , agree on the following: article 1 persons covered this AGREEMENT shall apply to persons Contract, one or both of the Contracting States residents.
Article 2 taxes covered by the AGREEMENT. This agreement applies to income and capital taxes imposed by a Contracting State or of its political or administrative unit of local government in good regardless of the method of collecting the tax.
2. On the income and capital taxes, regarded all taxes imposed on total income, total capital or income or capital, including taxes on the capital gains of the movable or immovable property seizures, as well as taxes on capital appreciation.
3. The existing taxes to which this agreement applies, in particular, is: (a)) in the Russian Federation: (i) the profit tax;
(ii) the individual income tax;
(iii) Organization of property tax; and (iv) citizens property tax;
(b)) in the Republic of Latvia: (i) the corporate income tax;
(ii) the individual income tax; and (iii) the property tax.
4. This agreement shall also apply to the visitors identical or substantially similar income or capital taxes, adding to or replacing the existing taxes are introduced after the date of signature of this agreement. The competent authorities of the Contracting States inform each other of any substantial amendments to this country in the relevant tax legislation.
Article 3 General definitions 1. If the context does not otherwise specified, then this risk‐adjusted Treaty: a) the terms "Contracting State" and "the other Contracting State" mean depending on the context of the Republic of Latvia or in the Russian Federation;
(b)), the term "Russian Federation" means the territory of the Russian Federation, as well as its exclusive economic zone and the continental shelf, as defined in accordance with international law, including the 1982 UN Convention on the law of the sea;
(c)), the term "Latvia" means the territory of the Republic of Latvia, as well as its exclusive economic zone and the continental shelf, as defined in accordance with international law, including the 1982 UN Convention on the law of the sea;
(d)) the term "person" means a natural person, company, or any other Association of persons;
e the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association;
(f) the terms ") of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State;
(g)) the term "international traffic" means any transport by a ship, aircraft, car or rail transportation by the company of a Contracting State, except for the cases when the vessel, aircraft, vehicle or rail vehicle moves only in the other Contracting State;
h) the term "competent authority" means: (i) in the Russian Federation-Russian Federation Ministry of finance or its authorised representative;
(ii) in Latvia, the Ministry of finance or its authorised representative;
I) the term "national" means: (i) any natural person who has the nationality of a Contracting State;
(ii) any legal person, partnership or association, whose status as the result of contracting in force in national legislation.
2. the Contracting States in the application of this agreement, all terms not defined therein, have the meaning they have the respective Contracting State laws relating to taxes covered by the agreement, unless the context is otherwise, and the risk‐adjusted State the relevant tax legislation meaning prevails over other laws of this state the intended meaning.
Article 4 resident 1. In this agreement, the term "resident of a Contracting State" means any person who, under the laws of this State is subject to taxation on the basis of the place of residence, residence, location management, place of incorporation (registration) or any other similar criteria, and also includes the respective country, its political entity or local authority. However, this term does not include those individuals in that State taxes are imposed only in respect of their income from this country to the existing sources of profit or the capital.
2. where, in accordance with the provisions of the first subparagraph, an individual is a resident of both Contracting States, its status would be as follows: (a) the person is considered to be) only for residents of the country in which they are habitually resident; If you are habitually resident in two countries, this person shall be deemed to be a resident only of the State, with which it has closer personal and economic relations (Centre of vital interests);
(b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it is not a permanent residence in one of the two countries, this person shall be deemed to be a resident only of the State in which it is customary in the home;
c) if that person normally home in both countries or is not one of them, it is considered to be the only resident in the country, which is a national of that person;
(d)) if that person is a national of both States or no, the national competent authorities of the Contracting States shall settle the question by mutual agreement.
3. where, in accordance with the provisions of the first subparagraph, a person who is not a natural person, is a resident of both Contracting States, the competent authorities must seek to resolve the matter by mutual agreement and determine the mode of application of the agreement to such person. If such an agreement does not exist, then the application of the Treaty, that person will not be entitled to claim any tax benefits granted under this agreement.
5. pantsPASTĀVĪG representation 1. In this agreement, the term "permanent establishment" means a fixed place of business of the company, which is wholly or partly carried on business.
2. The term "permanent establishment" includes: (a)) control location;
b) branch;
c) Office;
(d) a factory;)
e a workshop, and f)) mine shaft, oil or gas extraction sites, quarries or any other place of extraction of natural resources.
3. A building site, a construction, Assembly or installation project or supervisory activities associated with them are considered permanent representation only if these works, projects or activities take longer than nine months.
4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall not include: (a) the use of buildings and equipment) only and exclusively the goods belonging to, or for the storage of the products demonstrated or supplies;
(b) goods belonging to the company) or article items intended solely for storage, demonstration or delivery;
(c) the goods belonging to the company) or article items intended exclusively for processing in the other company.
(d) the specific site) designed exclusively for the purchase of goods or products to your company's needs or the collection of information for the company's needs;
e) specific action site intended solely to carry out the business of any other preparatory or ancillary activities;
f) specific action site intended only and only to deal with a) to (e)) the following, in any combination thereof, if the combination of the action are generally preparatory or auxiliary character.

5. Notwithstanding the first and second subparagraph, if the person is not referred to in the sixth paragraph of the status of independent agent, running your business, and it has empowered the State to enter into contracts on behalf of the company, and it constantly uses this power, then in all activities carried out by such person for your business, it is considered that the company has a permanent establishment in the country concerned, except where that person is carried out only in the fourth paragraph, the proposed action that perform certain actions in place, the place of action under the said part is not considered permanent representation.
6. It is considered that the company does not have a permanent establishment in the Contracting State where the undertaking is established in that country, using only the broker, agent or any other agent of an independent status, provided that such persons perform their normal business activities.
7. the fact that the company is a resident of a Contracting State-controlled company is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking in itself does not mean that any of these companies is the second permanent representation of society.
Article 6 INCOME from real property 1. income which a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State taxes.
2. The term "immovable property" shall have the meaning which it has its laws and regulations of a Contracting State in which the property concerned is located.
In any case, this term covers property which belongs to real estate property including livestock and equipment used in agriculture and forestry, rights to which the land ownership rules, any similar right to acquire immovable property, rights, known as real-estate usage and rights to variable or fixed payments as consideration for the mineral deposits, natural ore and other natural resources, or the right to use them. Ships, aircraft, road and rail transport are not considered real estate.
3. The provisions of the first subparagraph are applied in respect of income from real estate direct use, letting or use in any other way.
4. If the company shares, the share capital or other corporate rights ownership gives this part of fixed capital stock, or the corporate owner of the rights entitled to the company's holding of real property, the income from the direct use, letting or use in any other manner may impose taxes in the Contracting State in which the immovable property is situated.
5. the first, third and fourth subparagraphs terms also apply in relation to income from the company's real estate, as well as income from real property used for independent individual services.
Article 7 business profits 1. Contracting State company profits are taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent representation of the existing there. If the enterprise carries on business in that way, the company's profits may impose taxes in the other country, but only to the profit, which can be attributed to the permanent establishment.
2. in accordance with the provisions of the third subparagraph, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit amount as it would if it had been separated and independent company that performs the same or similar business activities under the same or similar conditions and independently carry out transactions with the company that it is a permanent establishment.
3. in determining the profits of the permanent representation are allowed to deduct the deductible expenses incurred by permanent missions to the needs of the country or elsewhere, including the actions and general administrative costs.
4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between the IT departments, the second part does not prohibit Contracting State as usual after this principle to determine the profit for tax purposes; However, the method of distribution must be such that the result matches the principles contained in this article.
5. On the permanent representation of the profits not only because it has purchased the goods or products for the company, which is the permanent representation.
6. for the purposes of applying the provisions of the preceding paragraph, the profits attributed to the permanent establishment shall be determined each year by the same method, except if there is sufficient reason to do otherwise.
7. If the profit is included in the other articles of this agreement are considered separate income type, this article shall not affect the other provisions of this article.
Article 8 international traffic revenues 1. Contracting State company profits gained from ships, aircraft, car or rail transport in international traffic, the use of taxable only in that State.
2. the application of this article, profits from the vessel, aircraft, car or rail transport for the use in international traffic shall also include: (a)), profit from the aircraft, car or rail transport rentals without crews and supply; and (b)) profit from containers (including trailers and related equipment for the transport of containers) use, maintenance or rental of goods or products;
If such lease or such use, maintenance or rental, as the case may be, takes place in addition to the company's ships, aircraft, car or rail transport for use in international traffic.
3. The first and second subparagraph shall also apply to profits from the participation in a pool, joint business or international traffic transport agency.
Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participate in the company of the other Contracting State, in the controls or owns part of the company's capital, or b) the same persons directly or indirectly participating in the enterprise of a Contracting State in the other Contracting State and enterprise management, controls or owns part of the company's capital, and in any of these cases, these two companies in commercial or financial relations are created or established by the rules different from those provisions that the force between two independent enterprises, then any profits which would, but for one of the companies affected by the above provisions did not have, can be included in the company's profits, and it may be appropriate to impose taxes.
2. where a Contracting State includes in the profits of an enterprise of that State and taxes accordingly profits on it, for the second State of the other Contracting State has been taxed, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, then, if the other country so deemed valid , it shall take the appropriate adjustment for the tax, which is imposed on the profits of the second State. In determining this adjustment, take into consideration other provisions of this agreement and, if necessary, the competent authorities of the Contracting States for consultations.
Article 10 dividends 1. Dividends company-a resident of a Contracting State in the other Contracting State, the cost of the resident may be taxed in that other State taxes.
2. However, such dividends may also impose taxes under the national laws of the Contracting State of which the resident is a company that pays dividends, but if this true owner of dividends is resident of the other Contracting State, the tax shall not exceed: a 5 per cent of the dividend) total, if real owner of dividends is a company (other than a partnership), which directly manages at least 25 percent of the company capital that pays dividends, and the invested capital exceeding seventy-five thousand United States dollars (us $75000) or such amounts equivalent in national currency of the Contracting States;
b) 10 per cent of the total dividends in all other cases.
This part shall not affect the taxation of company profits from which dividends.
3. The term "dividends" in this article means income from shares or other equity rights to participate in profits, not claims, as well as income from other rights which, in accordance with the laws of the State of which the resident is a company that performs the distribution of profits, subject to the same taxation treatment as income from shares or share capital.

4. the first and second subparagraphs shall not apply, if the true owner of dividends, who is a resident of a Contracting State, carries on business in the other Contracting State of which the dividends is resident in the firm's costly using existing permanent representation there, or give independent personal services in the other State through a permanent base located there, and where participation, which is paid out in dividends, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14.
5. If company-a resident of a Contracting State derives profits or income in the other Contracting State, that other State may not impose any taxes or these companies paid dividends, except where the dividends are paid to a resident of the other State, or if the participation of which is paid out in dividends, is actually related to the permanent representation or permanent base in another country; nor does it impose a duty of retained earnings retained earnings of the company, even if the dividends paid or retained earnings consists in whole or in part from the other country of profit or income.
Article 11 interest 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes.
2. However, such interest may also impose taxes according to relevant national laws in the Contracting State in which they arise, but, if the interest owner is implemented on the territory of the other Contracting State, a resident of the tax shall not exceed: a 5 per cent of the percentage) of the total, which is paid on any loan which the Contracting State bank or other financial institution has granted the bank of the other Contracting State or to another financial institution , b) 10 per cent of the total interest in all other cases.
3. Notwithstanding the provisions of the second paragraph, interest arising in a Contracting State and which the beneficiary and owner is implemented on the territory of the other Contracting State Government, including its political and administrative units and local governments, the central bank or any other this Government fully-owned financial institution, or the interest on the loans with a guarantee given by the Government, the first in that country are exempt from taxation.
4. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage and whether or not they have the right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes, which belong to these securities, bonds or debentures. Interest received on payments made within that time, are not considered interest for the application of the provisions of this article.
5. the first, second and third subparagraphs shall not apply, if the interest owner will exercise that is a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located therein, and of claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14.
6. If the payer of the interest is a resident of a Contracting State, it is considered that the interest generated in this country. If, however, the person paying the interest, whether that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which incurred debt obligations, for which you pay interest, and this interest is paid (bear) permanent establishment or a permanent basis, it is considered that this interest arises in the State in which the permanent establishment or fixed base.
7. If, on the basis of the special relationship between the payer and the interest percentage implemented owner or between both of them and some other person, the amount of interest that relate to debt claims, for which it is paid, exceeds the amount that would have been able to agree to the interest payer and the interest owner will, if implemented, they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the payment of the part which exceeds this amount, taxes are levied according to each Contracting State laws and regulations, taking into consideration other provisions of this agreement.
Article 12 ROYALTIES (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes.
2. However, such royalties may also impose taxes according to national regulations of the Contracting State in which it arises, but if the true owner of the royalties is a resident of the other Contracting State, the tax shall not exceed 5 per cent of the total royalties.
3. The term "royalties" in this article means payments of any kind received as a compensation for the use of any copyright or rights to use any copyright on literary, artistic or scientific work including cinematograph films, and films or recordings and other image or sound reproduction means the radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the transmission using satellite, cable, fibre optic cable, or similar technology, or the production, commercial, or scientific equipment, or for the right to use them, or for information concerning industrial, commercial or scientific experience.
4. The first and second subparagraphs shall not apply, if the true owner of the royalties, which is a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located there, and if the right or property for which the royalties are paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14.
5. If the payer of the royalties is a resident of a Contracting State, it is considered that the image occurs in the country. If, however, the person paying the royalties, whether or not that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, due to which a duty to pay the royalties, and if the payment of the royalties (bear) the Permanent Mission or a permanent basis, it is considered that the royalties arise in the State in which the permanent establishment or fixed base.
6. If, on the basis of the special relationship between the payer of royalties and royalties shall implement the owner or between both of them and some other person, the amount of the royalties exceeds the amount of royalties that would have been able to implement a single payer and the owner if they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the portion of the payment that exceeds this amount, is taxed in accordance with the national laws and regulations, taking into consideration other provisions of this agreement.
Article 13 capital gains 1. Capital gains, by a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real property, may be subject to taxes in the other country.
2. Capital gains, by a resident of a Contracting State derives disposes of shares, the share capital or of any comparable participation in society or another unit that more than 50 percent of the value of directly or indirectly derives from article 6 of the second Contracting State to an existing real property, may be taxed in that other State taxes.
3. Capital gains that accrued, disposing of property, which is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State, or disposing of property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which created the independent personal services, including capital gains from the alienation of such a permanent representation (alone or with the whole enterprise) or of such a disposal of the standing base can impose taxes in the other country.

4. Capital gains by the public company, which is used in international traffic of ships, aircraft, car or rail transport, benefit, disposal of such ships, aircraft, car or rail transport or disposal of the property, which belongs to the ships, aircraft, car or rail transport, is taxed only in the country.
5. the capital gains gained disposes of any property, other than the first, second, third and fourth estate, referred to in part are taxable only in the Contracting State of which the resident is the seizure of property.
Article 14 INCOME from independent personal services of a resident of a Contracting State 1 – natural persons income gained from providing professional services or other independent activities are taxable only in the country, except if that person needs their activities using it regularly available permanent base the second Contracting State. If you are using such a permanent base, the income may be subject to taxes in the other Contracting State but only to the extent that it is applicable to this permanent base. The application of this article, if a resident of a Contracting State-natural person resident in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any twelve month period commencing or ending in the taxation year, it is considered that the person uses regular access to permanent base in the other State and the income that accrued on the second country made the above actions are applied to this permanent base.
2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as doctors, lawyers, engineers, architects, dentists and accountants of independent operation.
Article 15 INCOME from dependent personal services 1.16, 18 and article 19 rules for payment of wages and other similar remuneration, by a resident of a Contracting State receives for gainful employment are taxable only in that State unless paid work is not performed in the other Contracting State. If the salaried work is performed in the other Contracting State, the remuneration received for it can impose taxes in the other country.
2. Notwithstanding the provisions of the first subparagraph, a consideration that a resident of a Contracting State receives for paid work that is performed in the other Contracting State, be taxable only in the first mentioned State if: (a) the beneficiary) is found in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxation year, and (b) the remuneration is paid), the employer that is not a resident of the other State, or the name of the employer, and c the remuneration is not paid) (bear) permanent representation or permanent base, used by the employer in the other country.
3. Notwithstanding the preceding provisions of this article remuneration received for paid work that is being done to a company of a Contracting State in international traffic of ships, used aircraft, car or rail transport, tax may be imposed in the country.
Article 16 DIRECTORS ' fees directors ' fees and other similar remuneration received by a resident of a Contracting State as the Board of directors or other similar institutions in society, which is a member of the other Contracting State, a resident may be taxed in that other State taxes.
Article 17 artists and athletes return 1. articles 14 and 15 of the regulations to the income of a resident of a Contracting State as izpildītājmāksliniek, such as a theatre, film, radio or television artist, or a musician, or as an athlete for your individual activities in the other Contracting State may be taxed in that other State taxes.
2. If izpildītājmāksliniek or athlete's income on his individual activity in the area in question is paid rather than izpildītājmāksliniek or athlete himself but to another person, to the following income regardless of the 7, 14 and 15 the provisions of article 1 may be subject to taxes in the Contracting State in which the activity or sports izpildītājmāksliniek.
3. The first and second subparagraphs shall not apply to income that izpildītājmāksliniek or athlete has learned about the activities performed in the Contracting State, if the visit to that State wholly or mainly financed from one or both of the Contracting States, the political entity or local authority, or, if this visit is organized in accordance with a special agreement of both countries on cooperation in the field of cultural or sports. In this case, the income shall be taxable only in the Contracting State of which the resident is izpildītājmāksliniek, or athlete.
Article 18 pensions 1. Pensions and other similar remuneration, by a resident of a Contracting State receives for previous paid employment are taxable only in that State.
2. However, such pensions and other similar remuneration paid to the other Contracting State, its political and administrative unit or municipality, or that are paid from funds established by them are taxed only in that other State.
Article 19 remuneration of public service 1 a) for salaries, wages and other similar remuneration, other than a pension, and a natural person the cost of Contracting State, its political and administrative unit or municipality of this State, entity or municipality services are taxable only in that State.
(b) However, such salaries), fees and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely to provide these services.
2.15, 16 and article 17 shall apply to salaries, wages and other similar remuneration paid for services rendered in connection with a Contracting State, its political and administrative units or authorities of the business.
Article 20 payments to students, trainees and apprentices payments which a residence, study or internship needs receives a student, trainee or apprentice who is, or immediately before the arrival of the Contracting State had the other residents of a Contracting State, and who first arrived in that country solely for the purpose of study or internship, in this country are not taxed if such payments are from sources that are not in the country.
Article 21 offshore ACTIVITIES in zone 1. The provisions of this article are applied regardless of this article 5 to article 20 of the regulations.
2. In this article the term "offshore area" means the action of the ice shelf of a Contracting State that is associated with the zone in the country and the existing marine subsoils and there existing natural resource exploration or exploitation.
3. Person-resident of a Contracting State in the other contracting action country shelf area, in accordance with the fourth subparagraph shall be considered to be a business that is carried on in the other State through a permanent establishment there existing or permanent base.
4. the provisions of the third paragraph do not apply if the action is carried out in the area of the shelf during the period or periods not exceeding in the aggregate 30 days in any twelve month period. The application of this part: (a)) people linked with another person, the action shelf zone, is considered the other people take action, if this action is essentially the same as its first performed in person, except that, if action is taken at the same time as the person's own actions;
(b)) a person shall be deemed to be associated with another person if one of them directly or indirectly controls the other or a third person or third party directly or indirectly controls both parties.
5. to pay for salaries and other similar remuneration received by a resident of a Contracting State for gainful work associated with the activity zone the second shelf of the Contracting State may be taxed in that other State taxes to the extent that this work has been done in the other country shelf area. However, such remuneration shall be taxable only in the first country, where the paid work is done in the right of the employer who is not a resident of the other State, and if the duration of a maximum 30-day period or periods in any twelve month period.
6. income which a resident of a Contracting State alienates a benefit: a) research or exploitation rights; or (b)) property, which hosted the second Contracting State and used in connection with the operation of these other national ice zone; or (c)) or the share capital of shares that its value or values most directly or indirectly derived from the above rights or property, or the rights and property of these together;
may impose taxes in the other country.
In this part, the term "exploration or exploitation rights" means the right to property, which can be generated by activities in the other Contracting State, or ice the right to participation in the ownership or profit to be gained in this property.

Article 22 other income 1. in accordance with the provisions of part two of the other Contracting State, a resident of the income that is not stipulated in the preceding articles of this agreement, regardless of their sources is taxed only in the country.
2. The provisions of the first subparagraph shall not apply to income, other than income from the second paragraph of article 6, as defined in the property, if the income beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation of the existing there, or give independent personal services in the other State through a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the conditions of this contract apply 7. the provisions of article 14.
3. Notwithstanding the first and second part, any income gambling and lottery winnings, which arise in the other Contracting State may also impose taxes in the other Contracting State.
Article 23 capital 1. Capital, consisting of article 6 that a resident of a Contracting State of the real estate, which is situated in the other Contracting State may be taxed in that other State taxes.
2. Capital, which consists of movable property that is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State or capital, which consists of movable property that belongs to a resident of a Contracting State, to the standing base of independent personal services in the other Contracting State may be taxed in that other State taxes.
3. Capital, consisting of ships, aircraft, car or rail transport that Contracting State company used for international traffic, as well as movable property that belong to these vessels, aircraft, car or rail transport, is taxed only in the country.
4. all other Contracting State, a resident of the capital items are taxable only in that State.
Article 24 avoidance of double taxation methods 1. for residents of the Russian Federation, double taxation is avoided as follows: Where a resident of the Russian Federation derives income or owns capital which, in accordance with the terms of this agreement may be subject to taxes in the Republic of Latvia, the amount of tax on that income or capital payable in Latvia, you can allow the Russian Federation to reduce the amount of tax. However, this amount of reduction shall not exceed the amount of tax on the income or the capital which has been calculated in accordance with the laws of the Russian Federation and rules.
2. for residents of the Republic of Latvia, double taxation is avoided by the following: (a) where a resident of Latvia) derives income or owns capital which, in accordance with the terms of this agreement may be subject to taxes in the Russian Federation, then, unless national legislation is more favourable rules, the Republic of Latvia permit: (i) reduce the resident's income tax on the amount that is equal to the Russian Federation paid the income tax;
(ii) reduce the resident's capital tax on an amount equal to the Russian Federation paid capital duty.
These reductions, however, in no case, exceed the income tax or capital tax, part of which is calculated in the Republic of Latvia before the application of this reduction and, depending on the circumstances of which is attributable to the income or the capital which may be subject to taxes in the Russian Federation.
(b)) to apply a) point if the company-a resident of Latvia receives a dividend from a company-resident of the Russian Federation, in which it owns at least 10 per cent of the shares or the share capital with full voting rights, the tax paid in the Russian Federation are included not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the profits of the company out of which the dividend was paid.
25. Article 1 of the Prevention of discrimination on the nationals of a Contracting State in the other Contracting State not subject to taxation or related requirements that are different or more burdensome than the taxation or the related requirements which, in the same circumstances, in particular in the context of residence applies or may apply to the nationals of the other. This provision shall, notwithstanding the provisions of article 1, also apply to persons who do not have one or both of the Contracting States residents.
2. For stateless persons – residents of a Contracting State in one of the Contracting States not subject to taxation or related requirements that are different or more burdensome than the taxation or the related requirements which, in the same circumstances, in particular in the context of residence applies or may apply to nationals of the country concerned.
3. Taxation the company of a Contracting State to the permanent representation the other Contracting State may not be less favourable than those of other taxation public companies which perform the same operation. This provision should not be interpreted that it imposes on the Contracting State the obligation to grant the other Contracting State any personal relief to residents, discount and reduction in relation to taxation, which this country give its residents, in the light of their civil status or family responsibilities.
4. except where applicable to article 9, the first paragraph of article 11, or the seventh subparagraph of article 12 of the sixth subparagraph, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident by establishing this company's taxable profits, must be deducted subject to the same provisions as if they were to be paid to the first residents of that State. Similarly, the enterprise of a Contracting State in the other Contracting State debt residents, establishing this company's taxable capital, is to be deducted by the same rules as if they would apply to the first residents of that State.
5. the Contracting State whose capital, in whole or in part, directly or indirectly, belongs to one or more residents of the other Contracting State, or to their directly or indirectly controlled by those residents, the first State may not be subject to any taxation or any requirements associated with it, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or that are more burdensome on them.
6. The provisions of this article, notwithstanding the provisions of article 2, apply to taxes of every kind and name.
Article 26 mutual conciliation procedure 1. If a person believes that one or both of the Contracting States concerning this person causes or will cause the taxation which does not comply with the terms of this agreement, that person may, irrespective of the country in national legislation that remedies to submit complaints to the competent authority of the country of which the person is resident, or if the complaint relates to article 25, first subparagraph, of the Contracting State-competent authority that national is that person. The complaint shall be submitted for review within three years of the first notification of the action which led to the terms of this agreement without corresponding taxation.
2. If the competent authority deems the complaint to be justified and even fail to reach a satisfactory solution, it will endeavour to agree with the other Contracting State, the competent authority, to prevent the contract inappropriate taxation. Any such agreement is reached is due irrespective of the Contracting State, national laws and the time limits laid down.
3. the national competent authorities should seek mutual agreement resolve any difficulties or eliminate doubts which may arise in the interpretation or application of this agreement. They may also consult to avoid double taxation in this contract in the event of unforeseen circumstances.
4. in order to reach agreement on these issues in the preceding subparagraph, the competent authorities of the Contracting States may communicate directly with one another, as well as following an exchange of views can take place with the competent authorities of the Contracting States, or their representatives in a joint Commission.
Article 27 Exchange of information

1. The competent authorities must exchange information as required to comply with the provisions of this agreement or a Contracting State's national legislation in respect of all the type and name of the taxes imposed on the Contracting State, its political and administrative units or local authorities, completion, to the extent that such taxation is not contrary to the agreement. 1 and 2 of the Treaty, article does not limit the exchange of information. Any information received by a Contracting State, should be considered as sensitive as information that is obtained in accordance with the laws of this State and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the first sentence, the calculation of tax collection, the use of coercive measures, trials or appeals in respect of those taxes. Such persons or authorities, this information must be used only for the purposes mentioned above. They may disclose the information in public hearings or in judgements.
2. in no case shall the provisions of the first subparagraph may not be explained so that they bind the Contracting State the obligation: a to carry out administrative measures), which does not comply with one or other of the contracting national legislation and administrative practice;
(b)) to provide information that is not available under one or the other national legislation or administrative practice generally applicable;
(c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or process a transaction, or to provide information, the disclosure of which would be contrary to public policy (ordre public).
Article 28 assistance in tax collection 1. the Contracting States undertake to provide each other with the help of taxpayer's outstanding collection of taxes to the extent that the amount is finally determined in accordance with the help of the requesting Contracting State legislation.
2. If a Contracting State requires you to provide assistance in tax collection and the collection has agreed to the other Contracting State, that other State these taxes are levied in accordance with the laws and regulations applicable to this second state tax revenues, and as taxes be levied should they tax.
3. Any Contracting State, the claim must be accompanied by a document that, in accordance with the laws of this State affirm that the taxpayer's tax debt is fixed.
4. where a Contracting State tax requirements have not been definitive, as it is established in court or otherwise, this country to keep its revenues, request the other Contracting State of its right to the temporary measures for the conservation of these resources, which are applicable under the latter's national laws and regulations. If the other State agrees to execute such a requirement, this second State these temporary measures as tax debt first to that country would be a tax debt to the other country.
5. the requirement under the third and fourth part provides the only Contracting State if that State is not available in sufficient tax property to recover the outstanding tax amount.
6. the Contracting State in which, in accordance with the provisions of this article are charged tax, paid to the Contracting State of which the good this tax was levied, the amount of tax collected, from which, if necessary, the seventh part of the ESL) referred to in paragraph (b) extraordinary expense amount.
7. If one of the two competent authorities of the Contracting States have agreed on different rules, it is considered that: a) Contracting State aid during the current expenses shall be borne by that State;
b) Contracting State assistance during emergency expenses shall be borne by the other State and they have to pay no matter what the amount of the tax is levied in the other State.
As soon as a Contracting State anticipates that extraordinary costs may occur, it shall immediately inform the other Contracting State and indicate the possible extent of this expenditure.
8. In this article the term "taxation" means the taxes covered by the agreement, and include any related interest and penalties.
Article 29 diplomatic mission and consular staff nothing in this Agreement shall affect the diplomatic missions or consular posts personnel fiscal privileges which it applied in accordance with international law, the General rules or specific agreement terms.
Article 30 entry into force 1. Each Contracting State through diplomatic channels in writing notify the other country that has met the State Contracting laws and procedures laid down for the entry into force of this Treaty.
2. This Treaty shall enter into force with the first subparagraph, the last statement date and its provisions in both Contracting States shall apply: (a)) in respect of taxes withheld at the time the cost-income accruing on the first day of January or after the calendar year following the year in which the entry into force of this Treaty;
(b)) in the case of other income taxes and capital taxes-taxes payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the entry into force of this Treaty.
Article 31 termination this Agreement shall remain in force as long as one Contracting State it shall be terminated. Each Contracting State may terminate the agreement through diplomatic channels by giving written notice of termination at least six months before any end of the calendar year following the five-year period after the date of entry into force of the Treaty. In this case, the agreement of both Contracting States shall cease: (a)) in respect of taxes withheld at the time the cost-income accruing on the first day of January or after the calendar year following the year in which the notice has been filed;
(b)) in the case of other income taxes and capital taxes-taxes payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the notice has been filed.
The agreement is drawn up in two copies in Moscow 2010. on 20 December, Russian, Latvian and English languages, each text being equally authentic. Different case is decisive for the interpretation of the text in English.
Government of the Republic of Latvia Artis camphor in Russian Federation Government Sergey Shatalov signed a PROTOCOL of the Government of the Republic of Latvia and the Government of the Russian Federation Treaty on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter the agreement), the parties have agreed upon the following provisions, which is to form an integral part of this agreement.
1. as regards article 13: the Contracting States understand that all income and capital gains of the country's real estate transfer tax may be imposed in the Contracting State in accordance with article 13 of the Treaty, the provisions of the first subparagraph.
2. in relation to article 27: If a Contracting State in accordance with this article shall be required to provide the information to the other Contracting State shall obtain the information to which the request relates in the same way and as much as that State's first duty should this other State tax imposed on this second State, even if the requested information to the other country does not need your taxation needs.
Contracting State may refuse to provide information about taxpayer accounts and transactions only because its holder is a bank or other financial institution.
However, the country to which the request for information, not to take administrative measures, which are not allowed under the requesting national laws or practice, and do not provide any information that is not obtainable under the laws of the requesting State or generally applicable administrative practice.
3. Both the competent authorities of the Contracting States shall not require certificate (Apostille) any documents required for the application of this agreement.
4. It is understood that a resident of a Contracting State shall not be entitled to receive any of this Treaty tax reduction or exemption for the income that is received from the other Contracting State, if both competent authorities of the Contracting States for mutual consultations is established that such resident or main purpose for or one of the main goals has been to use in this agreement, benefits, which it would not otherwise be available.
The Protocol is drawn up in two copies in Moscow 2010. on 20 December, Russian, Latvian and English languages, each text being equally authentic. Different case is decisive for the interpretation of the text in English.
Government of the Republic of Latvia Artis camphor in Russian Federation Government Sergey Shatalov
 
 

Agreement BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the RUSSIAN FEDERATION FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income AND ON CAPITAL the Government of the Republic of Latvia and the Government of the Russian Federation, an agreement the conclud (menu rngton Line4) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital and with a view to promote economic cooperation between the two countries, have agreed as follows: article 1 PERSONS COVERED this Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2 taxes COVERED 1. This agreement shall apply to taxes on income imposed on behalf of the Andean capital on (a) the Contracting State or of its political subdivisions or local authorities, irrespectiv of the manner in which they are levied.
2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovabl property, as well as taxes on capital appreciation.
3. The existing taxes to which the agreement shall apply in particular to: (a)) in the case of the Russian Federation: (i) the tax on profits of the organisation;
(ii) the income tax on individual;
(iii) the tax on property of the organisation; and (iv) the tax on property of the individual;
(b)) in the case of the Republic of Latvia: (i) the enterprise income tax;
(ii) the personal income tax; and (iii) the property tax immovabl.
4. This agreement shall apply also to any identical or substantially similar taxes on income or on capital which are imposed after the date of signature of this agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify the other of any substantial changes to each which have been made in their taxation laws of respectiv.
Article 3 GENERAL DEFINITION 1. For the purpose of this agreement, unless the context otherwise requires: a the term "a) Contracting State" and "the other Contracting State" mean the Republic of Latvia or the Russian Federation, as the context requires;
(b)), the term "the Russian Federation" means the territory of the Russian Federation as well as its exclusive economic zone and continental shelf, defined in accordanc with the international law, including the 1982 and the Law of the Sea Convention;
(c)), the term "the Republic of Latvia" means the territory of the Republic of Latvia as well as its exclusive economic zone and continental shelf, defined in accordanc with the international law, including the 1982 and the Law of the Sea Convention;
(d) the term "person") includes an individual, a company and any other body of persons;
e the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose;
(f) the term ") enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
g) the term "international traffic" means any transport by a ship, aircraft, road or railway vehicle operated by an enterprise of a Contracting State, except when the ship, aircraft, road or railway vehicle is operated solely between places in the other Contracting State;
h) the term "competent authority" means: (i) in the case of the Russian Federation-the Ministry of Finance of the Russian Federation or its authorised representative;
(ii) in the case of the Republic of Latvia-the Ministry of finance or its authorised representative;
(I) the term "national") means: (i) any individual possessing the nationality of a Contracting State;
(ii) any legal person, partnership or association deriving its status as such from the law in force in a Contracting State.
2. As regards the application of this agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has under the law of that State concerning the taxes to which the agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.
Article 4 resident 1. For the purpose of this agreement, the term "resident of a Contracting State" means any person who, under the law of that State, is liabl to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liabl to tax in that State in respect only of income from sources in that State or capital situated therein.
2. Where by reason of the provision of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests);
(b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode;
c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national;
(d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement.
3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to the settle the question by their mutual agreement and determin the mode of application of the agreement to such person. In the absence of such agreement, for the purpose of the agreement, the person shall not be entitled to claim any benefits provided by this agreement.
Article 5 permanent establishment 1. For the purpose of this agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
2. The term "permanent establishment" includes especially: a a place of management);
(b)) a branch;
c) an Office;
(d) a factory;)
e a workshop, and f)) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.
3. A building site, a construction, assembly or installation project or a supervisory activity connected therewith constitut a permanent establishment only if such site, project or activity lasts for a period of more than nine months.
4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;
(b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery;
(c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;
(d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;
e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character;
f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character.
5. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph.
6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other.
Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.

2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated.
The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of the law respecting landed property apply, any option or similar right to acquir-immovabl property rights, known as usufruc of immovabl property and rights to variable or fixed payments as considerations for the working of , or the right to work, mineral deposits, sources and other natural resources. Ships, aircraft, road and railway vehicles shall not be regarded as immovabl property.
3. The provision of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovabl property.
4. Where the ownership of shares or other corporate rights in a company the owner of entitl such shares or corporate rights to the enjoymen of immovabl property held by the company, the income from the direct use, letting, or use in any other form of such right may be taxed to the enjoymen in the Contracting State in which the immovabl property is situated.
5. The provision of paragraphs 1, 3 and 4 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services.
Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein , there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.
3. In determining the profits of a permanent establishment, there shall be allowed as a deduction in "those of the expense of deductibl which incurred for the purpose of the permanent establishment, including Executive and general administrative expense so incurred, whethers of in the State in which the permanent establishment is situated or elsewher.
4. Insofar as it has been customary in a Contracting State to determin the profits to be attributed to a permanent establishment on the basis of an apportionmen of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclud that Contracting State from determining the profits to be taxed by such an apportionmen as may be customary; the method of apportionmen, however, the adopted shall be such that the result shall be in accordanc with the principles led in this article.
5. From the profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
7. Where profits include items of income which the deal with separately in other articles of this agreement, then the provision of those articles shall not be affected by the provision of this article.
Article 8 profits FROM INTERNATIONAL transport 1. Profits derived by an enterprise of a Contracting State from the operation of ships, aircraft, road or railway vehicles in international traffic shall be taxabl only in that State.
2. For the purpose of this article, profits of an enterprise from the operation of ships, aircraft, road or railway vehicles in international traffic also include: a) profits from the rental on a barebo basis of a ship, aircraft, road or railway vehicles; and (b)) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;
where such rental or such use, maintenance or rental, as the case may be, is it the operations of incidentals ships, aircraft, road or railway vehicles by the enterprise in international traffic.
3. The provision of paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Article 9 ASSOCIATED enterprises 1. Where (a) an enterprise of a Contracting) State of directly or indirectly participat in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons directly or indirectly the participat in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State , and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State-and taxes accordingly-profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises , then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits, where that other State consider the adjustment justified. In determining such adjustment, due regard shall be had to the other provision of this agreement and the competent authorities of the Contracting States shall if the cessary not consult each other.
Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.
2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not (a) 12:5 per cent) of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends and the capital invested in seventy five exceeds 100 thousand United States dollars (75, 000 US dollars) or its equivalent in the national currencies of the Contracting States;
b) 10 per cent of the gross amount of the dividends in all other cases.
The provision of this paragraph shall not be affec the taxation of the company on the profits out of which the dividend is paid with.
3. The term "dividends" as used in this article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the taxation law of the State of which the company making the distribution is a resident.
4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply.

5. Where a company which is a resident of a Contracting State or of deriv profits income from the other Contracting State, that other State may not impost any tax on the dividends paid by the company, except insofar as such dividends to be paid to a resident of that other State or insofar as the holding in respect of which the dividend is paid is effectively connected with (a) a person with manent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits the to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State.
Article 11 interest 1-interest arising in a Contracting. The State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, such interest may also be taxed in the Contracting State in which it «arise and according to the law of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not (a) 12:5 per cent) of the gross amount of the interest on loans of any kind granted by a bank or other financial institution of a Contracting State to a bank or other financial institution of the other Contracting State;
b) 10 per cent of the gross amount of interest in all other cases.
3. Notwithstanding the provision of paragraph 2, interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including its political subdivisions and local authorities, the Central Bank or any financial institution wholly owned by that Government, or interest derived on loans guaranteed by that Government shall be main from tax in the first-mentioned State.
4. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage, and whethers or not carrying a right to participat in the debtor's profits and in particular, income from government securities and income from bonds or debentur, including premium and prizes attaching to such securities, bonds or debentur. Penalty charges for late payment shall not be regarded as interest for the purpose of this article.
5. The provision of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply.
6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated.
7. Where, by reason of a special relationship between the payer and the beneficial owner of interest or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement.
Article 12 to 1 to ROYALT Royalt arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, such may be taxed in royalt also in the Contracting State in which they «arise and according to the law of that State, but if the beneficial owner of the royalt to is a resident of the other Contracting State, the tax so charged shall not exceeds 100 5 per cent of the gross amount of the royalt.
3. The term "royalt" as used in this article means payments of any kind received as a considerations for the use of, or the right to use, any copyright of literary, artistic, or a scientific work, including cinematograph films and films or tapes and other means of image or sound reproduction for radio or television broadcasting, any patent, trademark, design or model , plan, secret formula or process, or for transmission by satellite, cable, optic fibre or similar technology, or for the use of, or the right to use any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.
4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply.
5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated.
6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, 12 the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement.
Article 13 CAPITAL gains 1. Gains derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State may be taxed in that other State.
2. Gains derived by a resident of a Contracting State from the alienation of shares or interests of any kind in comparabl in a company or other entity deriving more than 50 per cent of their value directly or indirectly from immovabl property referred to in article 6 and situated in the other Contracting State, may be taxed in that other State.
3. Gains derived from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services , including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State.
4. Gains derived by an enterprise of a Contracting State operating ships, aircraft, road or railway vehicles in international traffic from the alienation of such ships, aircraft, road or railway vehicles or movable property pertaining to the operation of such ships, aircraft, road or railway vehicles shall be only in the taxabl you state.
5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxabl only in the Contracting State of which the alienator is a resident.
Article 14 income FROM independent PERSONAL services

1. Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other activities of an independent character shall be taxabl only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributabl to that fixed base. For this purpose, where an individual who is a resident of a Contracting State stay in the other State for a period or Contracting period exceeding in the aggregate 183 days in any twelve month period commencing in or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to above that are performed in that other State shall be attributabl to that fixed base.
2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
Article 15 income FROM dependent PERSONAL services 1-subject to the provision of articles 16, 18 and 19, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in the fiscal year concerned , and b the remuneration is paid by), or on behalf of, an employer who is not a resident of the other State, and c the remuneration is not) borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provision of this article, remuneration derived in respect of an employment exercised aboard a ship, aircraft, road or railway vehicle operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Article 16 directors ' fees directors ' fees and other similar remuneration derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar body of a company which is a resident of the other Contracting State may be taxed in that other State.
Article 17 artistes AND SPORTSMEN OF INCOME 1. Notwithstanding the provision of articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman's, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsman's in his capacity as such notes to the accru entertainer or sportsman's himself but to another person, that income may, notwithstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman's are exercised.
3. The provision of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsman's if the visit to that State is wholly or mainly financed by one or both of the Contracting States, political subdivisions or local authorities thereof, or, if such a visit is organized in accordanc with the special cultural or sports agreements between the Contracting States. In such case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident.
Article 18 PENSION 1. Pension and other similar remuneration paid to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state.
2. However, such pension and other similar remuneration paid by, or out of funds created by, the other Contracting State or a political subdivision or a local authority thereof shall be only in the taxabl you others State.
Article 19 REMUNERATION FROM government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or a political subdivision or a local authority shall be only in the taxabl you state.
(b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services.
2. The provision of articles 15, 16, and 17 shall apply to salar, WAGs and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
Article 20 payments TO STUDENTS, AND the business of TRAINE APPRENTIC payments which a student, apprentice or business trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receive for the purpose of his maintenance, education or training shall not be taxed in that State , provided that such payments «arise from sources outside that State.
Article 21 offshore activities 1. The provision of this article shall apply notwithstanding the provision of Article 5 of the 20 of this agreement.
2. For the purpose of this article, the term "offshore activities" means activities carried on offshore in a Contracting State in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that State.
3. A person who is a resident of a Contracting State and carr to on offshore activities in the other Contracting State shall, subject to paragraph 4, be deemed to be carrying on business in that other State through a permanent establishment situated therein or a fixed base.
4. The provision of paragraph 3 shall not apply where the offshore activities are carried on for a period or periods not exceeding in the aggregate 30 days in any twelve month period.  For the purpose of this paragraph: a activities carried on offshore) by a person who is associated with another person shall be deemed to be carried on by the other person if the activities in question are substantially the same as those carried on by the first-mentioned person, except to the exten to that those activities are carried on at the same time as its own activities;
(b) a person shall be deemed) to be associated with another person if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or third persons.
5. Salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment connected with offshore activities in the other Contracting State may, to the the exten that the duties are performed offshore in that other State, be taxed in that other State.  However, such remuneration shall be taxabl only in the first-mentioned State if the employment is carried on for an employer who is not a resident of the other State for a period or periods and not exceeding in the aggregate 30 days within any twelve month period.
6. Gains derived by a resident of a Contracting State from the alienation of: (a) exploration or exploitation rights;) or b property situated in the other) Contracting State which is used in connection with the offshore activities carried on in that other State; or c shares deriving their value) or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together;
may be taxed in that other State.
In this paragraph the term "exploration or exploitation rights" means rights to assets to be produced by offshore activities carried on in the other Contracting State, or their interests in or to the benefit of such assets.
Article 22 OTHER income 1. Subject to the provision of paragraph 2, items of income of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Agreement shall be only in the taxabl you state.
2. The provision of paragraph 1 shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of articles 7 or 14, as the case may be, shall apply.
3. Notwithstanding the provision of paragraph 1 and 2 any income in the form of winning from gambling and lotter, arising in the other Contracting State, may be taxed in that also other Contracting State.
Article 23 CAPITAL

1. Capital represented by the immovabl property in the article referred to 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
3. Capital represented by ships, aircraft, road and railway vehicles operated in international traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships, aircraft, road and railway vehicles, shall be only in the taxabl you state.
4. All other elements of capital of a resident of a Contracting State shall be only in the taxabl you state.
Article 24 methods OF ELIMINATION OF double TAXATION 1. In the case of a resident of the Russian Federation, double taxation shall be avoided as follows: where a resident of the Russian Federation or of deriv income own capital which, in accordanc with the provision of this agreement, may be taxed in the Republic of Latvia, the amount of tax on that income or on capital payable in the Republic of Latvia , may be credited against the tax imposed in the Russian Federation. The amount of credit, however, shall note 12 the amount of the tax on that income or capital computed in accordanc with the laws and regulations of the Russian Federation.
2. In the case of a resident of the Republic of Latvia, double taxation shall be avoided as follows: (a)) where a resident of the Republic of Latvia or of deriv income own capital which, in accordanc with this agreement, may be taxed in the Russian Federation, unless a more favourabl treatment is provided in its national law, the Republic of Latvia shall allow : (i) as a deduction in "from the tax on the income of that resident, an amount equal to the income tax paid thereon in the Russian Federation;
(ii) as a deduction in "from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in the Russian Federation.
Such marbles in either case shall not, however, that about 12 of the income tax or capital tax in the Republic of Latvia, as computed before the deduction in "is given, which is attributabl, as the case may be, to the income or the capital which may be taxed in the Russian Federation.
(b)) For the purpose of sub-paragraph (a)), where a company that is a resident of the Republic of Latvia receive a dividend from a company that is a resident of the Russian Federation in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in the Russian Federation shall include not only the tax paid on the dividend , but also the appropriate portions of the tax paid on the underlying profits of the company out of which the dividend was paid.
Article 25 NON-DISCRIMINATION 1-nationals of a Contracting. State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensom than the taxation and connected requirements to which nationals of that other State in the same, in particular with circumstanc respect their residence, may be subjected to or. This provision shall, notwithstanding the provision of article 1, also apply to persons who are not residents of one or both of the Contracting States.
2. a person who with Stateles of residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensom than the taxation and connected requirements to which nationals of the State concerned in the same, in particular with circumstanc respect their residence, may be subjected to or.
3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of the of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowance, relief and reduction for taxation purpose on account of civil status or family responsibilities which it grants to its own residents.
4. Except where the provision of paragraph 1 of article 9, paragraph 7 of article 11, or paragraph 6 of article 12, apply, interest, and other disbursement royalt paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxabl profits of such enterprise, be-deductibl under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debt of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the capital of the taxabl such enterprise, be-deductibl under the same conditions as if they had been contracted to a resident of the first-mentioned State.
5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensom than the taxation and connected requirements to which other similar enterprises of the first-mentioned State may be subjected to or.
6. The provision of this article shall, notwithstanding the provision of article 2, apply to taxes of every kind and description.
Article 26 MUTUAL agreement procedure 1-where a person consider. that the actions of one or both of the Contracting States result or will result for him in taxation not in accordanc with the provision of this agreement, he may, irrespectiv of the remedies provided by the national law of those States, present his case to the competent authority of the Contracting State of which he is a resident or , if his case comes under paragraph 1 of article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordanc with the provision of the agreement.
2. The competent authority shall endeavour, if the objection to it appear to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordanc with the agreement. Any agreement reached shall be implemented notwithstanding any time limits provided for in the national law of the Contracting States.
3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any doubt arising as to the difficult or is it the interpretation or application of the agreement. They may also consult together for the elimination of double taxation in cases not provided for in the agreement.
4. The competent authorities of the Contracting States the may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs.
Article 27 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is not cessary for carrying out the provision of this agreement or of the domestic laws of the Contracting States concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the agreement. The exchange of information is not restricted by articles 1 and 2. Any information received by a Contracting State shall be treated as confidential in the same manner as information obtained under the national law of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of , or the determination of appeal in relations to the taxes referred to in the first line. Such persons or authorities shall use the information only for such purpose. They may be published by the information in disclos court proceedings or in judicial decisions.
2. In no case shall the provision of of paragraph 1 be construed so as to impost on a Contracting State the obligation: a to carry out administrative) measure the at variance with the laws and administrative practice of that or of the other Contracting State;
(b) to supply information which is not) obtainabl is under the laws or in the normal course of the administration of that or of the other Contracting State;
(c) to supply information which would disclos) any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Article 28 assistance IN the COLLECTION OF taxes 1. The Contracting States to lend assistance to undertak each others in the collection of the taxes owed table by (a) a taxpayer to the exten that the amount thereof has been finally determined according to the law of the Contracting State making the request for assistance.

2. In the case of a request by a Contracting State for the collection of taxes which has been accepted for collection by the other Contracting State, such taxes shall be collected by that other State in accordanc with the laws applicable to the collection of its own taxes and as if the taxes to be collected were its own SOS taxes.
3. Any request for collection by a Contracting State shall be accompanied by such certificate as is required by the law of that State to establish that the taxes owed table by the taxpayer have been finally determined.
4. Where the tax claim of a Contracting State has not been finally determined by reason of it being subject to appeal or other proceedings, that State may, in order to protect its revenues, request the other Contracting State to take such interim measure on its behalf for the conservancy with available axis to the other State under the law of that other State. If such request is accepted by the other State, such interim measure shall be taken by that of the other State as if the taxes owed table to the first-mentioned State were the own taxes of that other State.
5. A request under paragraphs 3 or 4 shall only be made by a Contracting State to the exten to that sufficient property of the taxpayer, the tax of the Owings is not available in that State for recovery of the taxes owed table.
6. The Contracting State in which the tax is recovered in accordanc with the provision of this article shall forthwith remi to the Contracting State on behalf of which the tax was collected the amount so recovered minus, where appropriate, the amount of extraordinary costs referred to in subparagraph 7 (b)).
7. It is understood that unless otherwise agreed to by the competent authorities of both the Contracting States: (a) the ordinary costs incurred by a) Contracting State in providing assistance shall be borne by that State;
(b) extraordinary costs incurred by a) Contracting State in providing assistance shall be borne by the other State and shall be payable regardless_of of the amount collected on its behalf by that other State.
As soon as a Contracting State of that extraordinary anticipate cost may be incurred, it shall so advise the other Contracting State and indicates the estimated amount of such costs.
8. In this article, the term "tax" means the taxes covered by the agreement and includes any interest and penalties relating theret.
Article 29 members OF DIPLOMATIC missions AND CONSULAR posts Nothing in this Agreement shall be affec the fiscal privilege of members of diplomatic missions or consular posts who are provided with such a privilege-under the rules of general international law or under the provision of special agreements.
Article 30 ENTRY into force 1. Each of the Contracting States shall notify to the other in writing through the diplomatic channel of the completion of the procedures required by the law applied in that Contracting State for the entry into force of this agreement.
2. The agreement shall enter into force on the date of the later of the notifications referred to in paragraph 1 and its provision shall have effect in both Contracting States: a in a) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the agreement enter into force;
(b)) in respect of other taxes on income and taxes on capital, for taxes for any fiscal year beginning chargeabl on or after the first day of January in the calendar year next following the year in which the agreement enter into force.
Article 31 TERMINATION this Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the agreement, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year beginning after the expiration of five years from the date on which the agreement enter into force. In such event, the agreement shall cease to have effect in both Contracting States: a in respect of taxes) withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given;
(b)) in respect of other taxes on income and taxes on capital, for taxes for any fiscal year beginning chargeabl on or after the first day of January in the calendar year next following the year in which the notice has been given.
Done at Moscow, "20" of December 2010, in duplicate, in the Latvian, Russian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall be the operative one.
For the Government of the Republic of Latvia Artis camphor For the Government of the Russian Federation Sergey Shatalov PROTOCOL At the signing of the agreement between the Government of the Republic of Latvia and the Government of the Russian Federation for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital (hereinafter referred to as "the agreement"), the undersigned have agreed upon the following provision which will form an integral on of the agreement: 1. With reference to article 13: the Contracting States understand that all income and gains arising from the alienation of property situated in a Contracting immovabl State may be taxed in that Contracting State in accordanc with the provision of paragraph 1 of article 13 of this agreement.
2. With reference to article 27: If information is requested by a Contracting State in accordanc with this article, the other Contracting State shall obtain the information to which the request relate in the same manner and to the same as if the exten tax of the first-mentioned State were the tax of that other State and were being imposed by that other State , event though that other State may not need such information for its own tax purpose.
A Contracting State may not to supply information on taxpayer declin's accounts and transactions solely because it is held by a bank or other financial institution.
However, the State has requested from the obligation to carry out administrative measure's that are not permitted under the law or practice of the requesting State or to supply items of information that are not under the law of the obtainabl or in the normal course of the administration of the requesting State.
3. The competent authorities of the Contracting States shall not both require Apostille for any documents not cessary for the application of this agreement.
4. It is understood that a resident of a Contracting State shall not be entitled to any reduction in or exemption from tax provided for in this axis of agreement on income derived from the other Contracting State if as a result of consultation between the competent authorities of both the Contracting States it is established that the main purpose or one of the main purpose of the creation or of the existenc of such resident was to obtain the benefits under this agreement that would not otherwise be available.
Done at Moscow, "20" of December 2010, in duplicate, in the Latvian, Russian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall be the operative one.
For the Government of the Republic of Latvia Artis camphor For the Government of the Russian Federation Sergey Shatalov