Vene Rock Esialgu Vene Rock alusel moodustatud suur mõju Lääne rokkmuusika ja kunsti lugu Venemaa, reeglina teostab akustiline kitarr. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to: a that permanent establishment; or b sales in that other State of goods and merchandise of the same or similar kind as sold through that permanent establishment; or c other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. They may disclose the information in public court proceedings or in judicial decisions. Where, however, the person paying the royalties, whether 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 royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. Abi osutamine laevadele 1.
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- Konsulaarasutuste avamine 1.
Persons Covered This Convention shall apply to persons who are residents of one or Keskmise liige Vene Foderatsiooni of the Contracting States. Article 2.
Taxes Covered 1. This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
Venemaa – Vikipeedia
There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
This Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes, which have been made in their respective taxation laws.
Interaktiivne kaart: Vene riigi kinnisvara Eestis | Eesti | ERR
General Definitions 1. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the Peenise mootmed soltuvalt kodakondsusest to which the Convention 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.
Sa oled siin
This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State. Where by reason of the provisions 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 settle the question by mutual agreement.
- Vasakpoolne partei.
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In the absence of such agreement, such person shall not be considered to be a resident of either Contracting State for purposes of enjoying benefits under the Convention.
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Permanent Establishment 1. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than 9 nine months.
Ainuüksi avalike andmete põhjal on Vene Föderatsioon võrreldes teiste välisriikidega Eestis kõige suurem kinnisvaraomanik. Ühelt poolt on see isegi ootuspärane, sest enamasti on tegu saatkonna töötajate korteritega, aga mitmel puhul tekitavad objektid küsimusi. Soovitame vaadata kaarti täisekraanil. Välisriikidel ei ole sisuliselt piiranguid Eestis kinnisvara soetada. Välja arvatud saatkonnahooned ja saadikute residentsid, ei pea Moskva, Washington ega Berliin eraldi aru andma, kui palju neile siin maid ja maju kuulub, vahendas "Pealtnägija".
Notwithstanding the provisions of paragraphs 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 conclude 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 undertakes for the enterprise, unless the activities of such person are limited 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 provisions of that paragraph.
An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that 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.
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 carries on business in that other State whether through a permanent establishment or otherwiseshall not of itself constitute either company a permanent establishment of the other.
Article 6. Income from Immovable Property 1. Income derived by 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.
The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of the law respecting landed property apply, any option or similar right to acquire immovable property, rights known as usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources.
Ships and aircraft shall not be regarded as immovable property. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property.
Where the ownership of shares or other corporate rights in a company entitles the owner of such shares or corporate rights to the enjoyment of immovable property held by the company, the income from the direct use, letting, or use in any other form of such right to enjoyment may be taxed in the Contracting State in which the immovable property is situated. The provisions of paragraphs 1, 3 and 4 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.
Business Profits 1. The profits of an enterprise of a Contracting State shall be Keskmise liige Vene Foderatsiooni only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to: a that permanent establishment; or b sales in that other State of goods and merchandise of the same or similar kind as sold through that permanent establishment; or c other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment.
Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in 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 Keskmise liige Vene Foderatsiooni a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and Keskmise liige Vene Foderatsiooni wholly independently with the enterprise of which it is a permanent establishment.
In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which Kesk-liikmeline foto incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.
The expenses to be allowed as deductions by a Contracting State shall include only expenses that are deductible under the national laws of that State.
Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.
No 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.
For the purposes 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. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not Keskmise liige Vene Foderatsiooni affected by the provisions of this Article.
Profits from International Traffic 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Article 9.
Venemaa Föderatsiooni Kommunistlik Partei – Vikipeedia
Associated Enterprises 1. Where a an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or b the same persons participate directly or indirectly 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.
Where a Contracting State includes in the profits of an enterprise of that State — and Keskmise liige Vene Foderatsiooni 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, if that other State considers that such adjustment is justified.
In determining such adjustment, due regard shall be had to the Keskmise liige Vene Foderatsiooni provisions of this Convention and the competent authorities of the Contracting States shall if necessary consult each other.
Article 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. 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 laws 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 exceed: a 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 directly invested by this beneficial owner is not less than seventy-five thousand United States dollars 75 USD or the equivalent amount in the national currency Suurenda seadme abil a Contracting State; b 10 per cent of the gross amount of the dividends in all other cases.
This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.