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At the moment of signing the Convention between the Government of the Republic of Austria and the Government of the Russian Federation for the avoidance of double taxation with respect to taxes on income and on capital, the undersigned have agreed that the following provisions shall form an integral part of the Convention:
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Ad Article 5:
If a resident of a Contracting State had in the other Contracting State a building site or construction or installation project on the date on which this Convention entered into force, and this project continues after that date, then the twelve months period shall be calculated from the date mentioned here, but this benefit shall in no case exceed twenty--four months from the date when the building site or construction or installation project started to exist.
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Ad Article 7:
It is understood that the term ``profits of an enterprise'' as used in Article 7 may include the profits derived by any partner from his participation in any partnership.
The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this provision.
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Ad Articles 7 and 9:
It is understood that in applying Article 7 and paragraph 1 of Article 9 the Russian Federation will not discriminate Austria against any other Member State of the European Union and vice versa.
Done in duplicate at Moscow, this 13th day of April 2000, in the German, Russian and English languages, all texts being equally authentic. In case there is any divergency of interpretation between the German and the Russian texts the English text shall be the operative one.
For the Government of the Republic of Austria:
Ferrero-Waldner
For the Government of the Russian Federation:
Iwanow
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