The Government of Russia and the Government of Malaysia wishing to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed on double taxation treaty.
Taxes covered
1. This Agreement shall apply to taxes on income imposed by a Contracting State, irrespective of the manner in which they are levied.
2. The taxes which are the subject of this Agreement are:
(a) In Malaysia:
(i) The income tax and excess profit tax;
(ii) The supplementary income tax, that is, development tax; and
(iii) The petroleum income tax.
(b) In Russia:
(i) The income tax on foreign legal persons;
(ii) The income tax on population; and
(iii) The tax on profits of a foreign participant of a joint venture, transferred abroad;
3. The Agreement shall also apply to any identical or substantially similar taxes on income 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 each other of important changes which have been made in their respective taxation laws, necessary for the implementation of this Agreement.
Business profits
1. The profits of a resident of a Contracting State shall be taxable only in that State unless the resident carries on business in the other Contracting State through a permanent establishment situated therein. If the resident carries on business as aforesaid, the profits of the resident may be taxed in the other State but only on so much thereof as is attributable to that permanent establishment.
Termination
This Agreement shall remain in effect indefinitely, but either Contracting State may terminate the Agreement, through diplomatic channels, by giving to the other Contracting State written notice of termination on or before 30 June in any calendar year after the year 1992. In such an event the Agreement shall cease to have effect in respect of taxes for the year of assessment beginning on the first day of January in the calendar year next following that in which the notice of termination is given and subsequent years of assessment.
