AGREEMENT BETWEEN
                  THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
                  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
Article 1
                  PERSONAL SCOPE
This Agreement shall apply to
                persons
                who are residents of one or both of the Contracting States.
Article 2
                  TAXES COVERED
- 
This Agreement shall apply to 
 taxes
 on income imposed on behalf of one of the Contracting States,
 irrespective of the manner in which they are levied.
- 
There shall be regarded as taxes 
 on
 income all taxes imposed on total income or on elements of income,
 including taxes on income from the alienation of movable or immovable
 property.
- 
The taxes to which the Agreement 
 shall apply are:(a) in 
 the case of the Republic of Indonesia:
 the income tax imposed under the Undang-undang Pajak Penghasilan 1984
 (Law No. 7 of 1983 as amended)
 (hereinafter referred to as “Indonesian Tax”);(b) in 
 the case of the Russian Federation:(i) the tax on 
 profits of enterprises and organisations;(ii) the tax on 
 income of individuals(hereinafter 
 referred to as “Russian Tax”).
- 
The Agreement shall also apply 
 to
 any identical or substantially similar taxes on income which are
 subsequently imposed after the date of signature of the Agreement in
 addition to, or in place of, those referred to in paragraph 3. The
 competent authorities of the Contracting States shall notify each other
 of any substantial changes which have been made in their respective
 taxation laws.
Article 3
                  GENERAL DEFINITIONS
- 
For the purposes of this 
 Agreement,
 unless the context otherwise requires:(a) the terms “Contracting State” and “the 
 other
 Contracting State” mean the Russian Federation (Russia) or the Republic
 of Indonesia (Indonesia);(b) the term “Russia” means the territory of 
 the Russian
 Federation as well as its exclusive economic zone and continental
 shelf, defined in conformity with the UN Convention on the Law of the
 Sea, 1982;(c) the term “Indonesia” means the territory 
 of the
 Republic of Indonesia as defined in its laws, and its exclusive
 economic zone and continental shelf in which the Republic of Indonesia
 exercises jurisdiction and sovereign rights in accordance with
 international law;(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 purposes;(f) the terms “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 or aircraft operated by a resident of a Contracting State,
 except when the ship or aircraft is operated solely between places in
 the other Contracting State;(h) the term “competent authority” means: – in the case of the Russian Federation — 
 the
 Ministry of Finance or its authorised representative;– in the case of Indonesia — the Minister 
 of Finance
 or his authorised representative;(i) the term “citizen” means any individual 
 possessing
 the citizenship of a Contracting State.
- 
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 which it has
 under the law of that State concerning the taxes to which the Agreement
 applies.
Article 4
                  RESIDENT
- 
For the purposes of the 
 Agreement,
 the term “resident of a Contracting State” means any person who, under
 the laws of that State, is liable to taxation therein by reason of his
 domicile, residence, place of incorporation, place of management or any
 other criterion of a similar nature.
- 
Where by reason of the 
 provisions
 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 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 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 does not have a permanent home
 available to him in either State, he shall be deemed to be a resident
 of the State in which he has an habitual abode;(c) if he has an habitual abode in both 
 States or in
 neither of them, the competent authorities of the Contracting States
 shall settle the question by mutual agreement.
- 
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 States shall
 settle the question by mutual agreement.
Article 5
                  PERMANENT ESTABLISHMENT
- 
For the purposes of this 
 Agreement,
 the term “permanent establishment” means a fixed place of business
 through which the business of an enterprise of a Contracting State is
 wholly or partly carried on in the other Contracting State.
- 
The term “permanent 
 establishment”
 includes especially:(a) a 
 place of management;(b) a 
 branch;(c) an 
 office;(d) a 
 factory;(e) a 
 workshop;(f) a 
 warehouse or premises used as sales outlet;(g) a 
 farm or plantation;(h) a mine, an oil or gas well, a quarry or 
 any other place of extraction or exploration of natural resources,
 drilling rig or ship used for exploration or exploitation of natural
 resources.
- 
The term “permanent 
 establishment”
 likewise encompasses:(a) a building site or a construction 
 project, or
 supervisory activities in connection therewith, but only where such
 site, project or activities continue in one of the Contracting States
 for a period of more than 3 months;(b) an assembly or installation project 
 which exists for
 more than 3 months;(c) the furnishing of services, including 
 consultancy
 services by an enterprise through employees or other personnel engaged
 by the enterprise for such purpose.
- 
Notwithstanding the preceding 
 provisions of this Article the term “permanent establishment” shall be
 deemed not to include:(a) the use of the facilities solely for the 
 purpose of
 storage or display 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 or
 display;(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 for collecting
 information, for the enterprise;(e) the maintenance of a fixed place of 
 business solely
 for the purpose of advertising, or for the supply of information;(f) the maintenance of a fixed place of 
 business solely
 for any combination of activities mentioned in subparagraphs (a) to
 (e), provided that the activity of the fixed place of business
 resulting from this combination is of a preparatory or auxiliary
 character.
- 
Notwithstanding the provisions 
 of
 paragraphs 1 and 2, where a person — other than an agent of an
 independent status to whom paragraph 7 applies — is acting in a
 Contracting State on behalf of an enterprise of the other Contracting
 State, that enterprise shall be deemed to have a permanent
 establishment in the first-mentioned Contracting State in respect of
 any activities which that person undertakes for the enterprise, if such
 a person:(a) has, and habitually exercises in that 
 State an
 authority to conclude contracts in the name of 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;(b) has no such authority, but habitually 
 maintains in
 the first-mentioned State a stock of goods or merchandise from which he
 regularly delivers goods or merchandise on behalf of the enterprise; or(c) manufactures or processes in that State 
 for the
 enterprise goods or merchandise belonging to the enterprise.
- 
An insurance enterprise of a 
 Contracting State shall, except with regard to reinsurance, be deemed
 to have a permanent establishment in the other Contracting State if it
 collects premiums in that other State or insures risks situated therein
 through an employee or through a representative who is not an agent of
 an independent status within the meaning of paragraph 7.
- 
An enterprise of a Contracting 
 State shall not be deemed to have a permanent establishment in the
 other Contracting State merely because it carries on business in that
 other Contracting State through a broker, general commissioner or any
 other agent of 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 otherwise), shall not of itself constitute either company a
 permanent establishment of the other.
Article 6
                  INCOME FROM IMMOVABLE PROPERTY
- 
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 “immovable property”
 shall have the meaning which it has under the law of the Contracting
 State in which the property in question is situated. Ships, boats and
 aircraft shall not be regarded as immovable property.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 general law respecting landed property apply, 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.
- 
The provisions of paragraph 1 
 shall
 also apply to income derived from the direct use, letting, or use in
 any other form of immovable property.
- 
The provisions of paragraphs 1 
 and
 3 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.
Article 7
                  BUSINESS PROFITS
- 
The profits of an enterprise of 
 a
 Contracting State shall be taxable 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; (b) sales in that other State of goods or 
 merchandise of
 the same or similar kind as those 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 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.
- 
In determining the profits of a
 permanent establishment, there shall be allowed as deductions expenses
 which are incurred for the purposes of the business 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.However, no such deduction
 shall be allowed in respect of amounts, if any, paid (otherwise than
 towards reimbursement of actual expenses) by the permanent
 establishment to the head office of enterprise or any of its other
 offices, by way of royalties, fees or other similar payments in return
 for the use of patents or other rights, or by way of commission, for
 specific services performed or for management, or, except in the case
 of [a] banking enterprise, by way of interest on money lent to the
 permanent establishment. Likewise, no account shall be taken, in the
 determination of the profits of a permanent establishment, for amounts
 charged (otherwise than towards reimbursement of actual expenses) by
 the permanent establishment to the head office of [the] enterprise or
 any of its other offices, by way of royalties, fees or other similar
 payments in return for the use of patents or other rights, or by way of
 commission for specific services performed or for management, or,
 except in the case of [a] banking enterprise, by way of interest on
 money lent to the head office of the enterprise or any of its other
 offices.
- 
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.
- 
Where profits include items of 
 income which are dealt with separately in other Articles of this
 Agreement, then the provisions of those Articles shall not be affected
 by the provisions of this Article.
Article 8
                  INCOME FROM INTERNATIONAL TRANSPORTATION
- 
Income from sources within a 
 Contracting State derived by a resident of the other Contracting State
 from the operation of ships in international traffic may be taxed in
 the first-mentioned State, but the tax imposed shall be reduced by an
 amount equal to 50 percent thereof.
- 
Income from the operation of 
 aircraft in international traffic shall be taxable only in the
 Contracting State of which person operating the aircraft is a resident.
- 
The provisions of paragraphs 1 
 and
 2 shall also apply to income from the participation in a pool, a joint
 business or an international operating agency.
Article 9
                  ADJUSTMENT OF TAXABLE INCOME
Where :
| (a) | a person who is a resident of a Contracting | 
| (b) | the same persons participate directly or | 
in either case conditions are made or imposed between the two persons
in their commercial or financial relations which differ from those
which would be made between independent persons, then any profits which
would, but for those conditions, have accrued to one of the persons,
but, by reason of those conditions, have not so accrued, may be
included in the profits of that enterprise and taxed accordingly.
Article 10
                  DIVIDENDS
- 
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 recipient is the beneficial owner of the dividends, the tax so
 charged shall not exceed 15 percent of the gross amount of the
 dividends.
- 
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
 corporate rights which is subjected to the same taxation treatment as
 income from shares by the laws of the State of which the company making
 the distribution is a resident.
- 
The provisions of paragraphs 1 
 and
 2 shall not apply if the beneficial owner of the dividends, being a
 resident of a Contracting State, carries on business in the other
 Contracting State of which the company paying the dividends is a
 resident, through a permanent establishment situated therein, or
 performs in that other State independent personal services from a fixed
 base situated therein, and the holding in respect of which the
 dividends are paid is effectively connected with such permanent
 establishment or fixed base. In such case, the provisions of Article 7
 or Article 14, as the case may be, shall apply.
- 
Notwithstanding any other 
 provision
 of this Agreement, where a company which is a resident of a Contracting
 State has a permanent establishment in the other Contracting State, the
 profits of the permanent establishment may be subjected to an
 additional tax in that other State in accordance with its law, but the
 additional tax so charged shall not exceed 12.5 percent of the amount
 of such profits after deducting therefrom income tax and other taxes on
 income imposed thereon in that other State.
- 
The rates of tax in paragraph 2 
 and
 in paragraph 5 of this Article shall not affect the rate of tax applied
 in any production sharing contracts or any other similar contracts
 relating to [the] oil and gas sector or other mining sector concluded
 by the Government of Indonesia, its instrumentality, its relevant state
 oil and gas company or any other entity thereof with a person who is a
 resident of the Russian Federation.
Article 11
                  INTEREST
- 
Interest arising in a 
 Contracting
 State and paid to a resident of the other Contracting State may be
 taxed in that other State.
- 
However, such interest may also 
 be
 taxed in the Contracting State in which it arises and according to the
 laws of that State, but if the recipient is the beneficial owner of the
 interest the tax so charged shall not exceed 15 percent of the gross
 amount of the interest.
- 
Notwithstanding the provisions 
 of
 paragraph 2, interest arising in a Contracting State and derived by the
 Government of the other Contracting State including local authorities
 thereof, a political subdivision or the Central Bank, shall be exempt
 from tax in the first-mentioned State.
- 
The term “interest” as used in 
 this
 Article means income from debt-claims of every kind, whether or not
 secured by mortgage and whether or not carrying a 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 attaching to such securities, bonds or debentures, as well as
 income assimilated to income from money lent by the taxation law of the
 State in which the income arises, including interest on deferred
 payment sales.
- 
The provisions of paragraphs 1 
 and
 2 shall not apply if the beneficial owner of the interest, being a
 resident of a Contracting State, carries on business in the other
 Contracting State in which the interest arises, through a permanent
 establishment situated therein, or performs 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 provisions of Article 7 or Article 14, as the case may be, shall
 apply.
- 
Interest shall be deemed to 
 arise
 in a Contracting State when the payer is that State itself, a political
 subdivision, a local authority, or a resident of that State. Where,
 however, the person paying the interest, 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 indebtedness
 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 to arise in the State in which the permanent establishment or
 fixed base is situated.
- 
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 interest, having
 regard to the debt-claim for which it is paid, exceeds the amount which
 would have been agreed upon by the payer and the beneficial owner in
 the absence of such relationship, the provisions of this Article shall
 apply only to the last-mentioned amount. In such case, the excess part
 of the payments shall remain taxable according to the laws of each
 Contracting State, due regard being had to the other provisions of this
 Agreement.
Article 12
                  ROYALTIES
- 
Royalties arising in a 
 Contracting
 State and paid to a resident of the other Contracting State may be
 taxed in that other State.
- 
However, if the recipient is the 
 beneficial owner of such royalties the tax so charged in the
 Contracting State in which they arise and according to the laws of that
 State shall not exceed 15 percent of the gross amount of the
 royalties.
- 
The term “royalties” in this 
 Article means payments, whether periodical or not, and however
 described, to the extent to which they are made as consideration for:(a) the use of, or the right to use, any 
 copyright,
 patent, design or model, plan, secret formula or process, trade mark or
 other like property or right; or(b) the use of, or the right to use, any 
 industrial,
 commercial or scientific equipment; or(c) the supply of scientific, technical, 
 industrial or
 commercial knowledge or information; or(d) the supply of any assistance that is 
 ancillary and
 subsidiary to, and is furnished as a means of enabling the initial
 application of, any such property or right as is mentioned in
 subparagraph (a), any such equipment as is mentioned in subparagraph
 (b) or any such knowledge or information as is mentioned in
 subparagraph (c); or(e) the use of, or the right to use: (i) motion picture films; or (ii) films or video tapes for use in 
 connection with
 television; or(iii) tapes for use in connection with radio 
 broadcasting;
 or(f) total or partial forbearance in respect 
 of the use
 or supply of any property or right referred to in this paragraph.
- 
The provisions of paragraphs 1 
 and
 2 shall not apply if the beneficial owner of the royalties, being a
 resident of a Contracting State, carries on business in the other
 Contracting State in which the royalties arise, through a permanent
 establishment situated therein, or performs in that other State
 independent personal services from a fixed base situated therein, and
 the right or property in respect of which the royalties are paid is
 effectively connected with such permanent establishment or fixed base.
 In such case, the provisions of Article 7 or Article 14, as the case
 may be, shall apply.
- 
Royalties shall be deemed to 
 arise
 in a Contracting State when the payer is that State itself, a political
 subdivision, a local authority, or a resident of that State. 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.
- 
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 royalties, having
 regard to the use, right or information for which they are paid,
 exceeds the amount which would have been agreed upon by the payer and
 the beneficial owner in the absence of such relationship, the
 provisions of this Article shall apply only to the last-mentioned
 amount. In such case, the excess part of the payments shall remain
 taxable according to the laws of each Contracting State, due regard
 being had to the other provisions of this Agreement.
Article 13
                  INCOME FROM ALIENATION OF PROPERTY
- 
Income derived by a resident of 
 a
 Contracting State from the alienation of immovable property referred to
 in Article 6 and situated in the other Contracting State may be taxed
 in that other State.
- 
Income 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. The term “movable property”
 means property which is recognised as such by the legislation of the
 Contracting State where such property is located.
- 
Income from the alienation of 
 any
 property other than that referred to in the preceding paragraphs shall
 be taxable only in the Contracting State of which the alienator is a
 resident.
Article 14
                  INCOME FROM INDEPENDENT PERSONAL SERVICES
- 
Income derived by a resident of 
 a
 Contracting State in respect of professional services or other
 activities of an independent character performed in the other
 Contracting State may be taxed in that other Contracting
 State.
- 
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
                  EMPLOYMENT INCOME
- 
Subject to the provisions of 
 Articles 16, 17, 18 and 19, salaries, wages and other similar
 remuneration derived by a resident of a Contracting State in respect of
 an employment shall be taxable 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.
- 
Notwithstanding the provisions 
 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 taxable only in the first-mentioned State if:(a) the recipient is present in that other 
 State for a
 period or periods not exceeding in the aggregate 90 days within any
 calendar year concerned; and(b) the remuneration is paid by, or on 
 behalf of, an
 employer who is not a resident of that 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.
- 
Notwithstanding the preceding 
 provisions of this Article remuneration derived in respect of an
 employment exercised aboard a ship or aircraft operated in
 international traffic shall be taxable only in the Contracting State of
 which the operator is a resident.
Article 16
                  DIRECTORS’ FEES
- 
Directors’ fees and other 
 similar
 payments derived by a resident of a Contracting State in his capacity
 as a member of the board of directors or any other similar organ of a
 company which is a resident of the other Contracting State may be taxed
 in that other State.
- 
The remuneration which a person 
 to
 whom paragraph 1 applies derives from the company in respect of the
 discharge of day-to-day functions of a managerial or technical nature
 may be taxed in accordance with the provisions of Article 15.
Article 17
                  PENSIONS
pension or other similar remuneration, paid from sources in a
Contracting State, shall be taxable only in that State.
Article 18
                  INCOME FROM GOVERNMENT SERVICE
| 1. | (a) | Remuneration, other than a pension, paid by | |
| (b) | However, such remuneration shall be taxable | ||
| (i) | is a citizen of that State; or | ||
| (ii) | did not become a resident of that State | ||
| 2. | The provisions of Articles 15, 16 and 17 | ||
Article 19
                  INCOME OF PROFESSORS, TEACHERS, RESEARCHERS, STUDENTS AND BUSINESS
                  APPRENTICES
- 
An individual who visits a 
 Contracting State at the invitation of that State or of a university,
 college, school, museum or other cultural institution of that State or
 under an official programme of scientific, research or cultural
 exchange for a period not exceeding two years primarily for the purpose
 of teaching, giving lectures or carrying out research at such
 institution and who is, or was immediately before that visit, a
 resident of the other Contracting State shall be exempt from tax in the
 first-mentioned State on his remuneration for such activity, provided
 that such remuneration is derived by him from the other Contracting
 State.
- 
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 receives for the purpose of his
 maintenance, education or training, shall not be taxed in that
 first-mentioned State, provided that such payments are made to him from
 the other Contracting State.
Article 20
                  OTHER INCOME
of income of a resident of a Contracting State which are not expressly
mentioned in the foregoing Articles of this Agreement and derived from
sources within the other Contracting State may be taxed in that other
State.
Article 21
                  METHOD OF ELIMINATION OF DOUBLE TAXATION
a resident of a Contracting State derives income from the other
Contracting State, the amount of tax on that income payable in that
other Contracting State in accordance with the provisions of this
Agreement, may be credited against the tax levied in the
first-mentioned Contracting State imposed on that resident. The amount
of credit, however, shall not exceed the amount of the tax of the
first-mentioned State on that income computed in accordance with its
taxation laws and regulations.
Article 22
                  NON-DISCRIMINATION
- 
Citizens 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
 burdensome than the taxation and connected requirements to which
 citizens of that other State in the same circumstances are or may be
 subjected.
- 
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 the enterprises of that other
 State carrying on the same activities.
- 
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 burdensome
 than the taxation and connected requirements to which other similar
 enterprises of the first-mentioned State are or may be subjected.
- 
The provisions of this Agreement 
 shall not be construed to restrict in any manner any exclusion,
 exemption, deduction, credit, or other allowance now or hereafter
 accorded by the laws of a Contracting State in the determination of the
 tax imposed by that State.
- 
In this Article the term 
 “taxation”
 means taxes which are the subject of this Agreement.
Article 23
                  MUTUAL AGREEMENT PROCEDURE
- 
Where a person considers that 
 the
 actions of one or both of the Contracting States result or will result
 for him in taxation not in accordance with the provisions of this
 Agreement, he may, irrespective of the remedies provided by the
 domestic 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 23, to that of the Contracting
 State of which he is a citizen. The case must be presented within two
 years from the first notification of the action resulting in taxation
 not in accordance with the provisions of the Agreement.
- 
The competent authority shall 
 endeavour, if the objection appears to it 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 accordance with this Agreement.
- 
The competent authorities of the 
 Contracting States shall endeavour to resolve by mutual agreement any
 difficulties or doubts arising as to 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.
- 
The competent authorities of the 
 Contracting States may communicate with each other directly for the
 purpose of reaching an agreement in the sense of the preceding
 paragraphs. The competent authorities, through consultations, shall
 develop appropriate bilateral procedures, conditions, methods and
 techniques for the implementation of the mutual agreement procedure
 provided for in this Article.
Article 24
                  EXCHANGE OF INFORMATION
- 
The competent authorities of the 
 Contracting States shall exchange such information as is necessary for
 carrying out the provisions of this Agreement or of the domestic laws
 of the Contracting States concerning taxes covered by the Agreement,
 insofar as the taxation thereunder is not contrary to the Agreement, in
 particular for the prevention of fraud or evasion of such taxes. The
 exchange of information is not restricted by Article 1. Any information
 received by a Contracting State shall be treated as secret in the same
 manner as information obtained under the domestic laws of that State.
 However, if the information is originally regarded as secret in the
 transmitting State it shall be disclosed only to persons or authorities
 (including courts and administrative bodies) involved in the assessment
 or collection of, the enforcement or prosecution in respect of, or the
 determination of appeals in relation to, the taxes which are the
 subject of the Agreement. Such persons or authorities shall use the
 information only for such purposes but may disclose the information in
 public court proceedings or in judicial decisions.
- 
In no case shall the provisions 
 of
 paragraph 1 be construed so as to impose on a Contracting State the
 obligation:(a) to carry out administrative measures at 
 variance
 with the laws and administrative practice of that or of the other
 Contracting State;(b) to supply information which is not 
 obtainable 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 
 disclose any
 trade, business, industrial, commercial or professional secret or trade
 process, or information, the disclosure of which would be contrary to
 State policy.
Article 25
                  MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR ESTABLISHMENTS
in this Agreement shall affect the fiscal privileges of the members of
diplomatic missions or consular establishments under the general rules
of international law or under the provisions of special agreements.
Article 26
                  LIMITATION OF BENEFITS
of the Contracting States shall endeavour to collect on behalf of the
other Contracting State such taxes imposed by that other Contracting
State as will ensure that any exemption or reduced rate of tax granted
under this Agreement by that other Contracting State shall not be
enjoyed by persons not entitled to such benefits. The competent
authorities of the Contracting States may consult together for the
purpose of giving effect to this Article.
Article 27
                  ENTRY INTO FORCE
- 
This Agreement shall enter into 
 force on the later of the dates on which the respective Governments
 notify each other in writing that the formalities required by the
 legislation of their respective States have been complied with.
- 
The provisions of this Agreement 
 shall have effect:(a) in respect of tax withheld at the 
 source, to income
 derived on or after 1 January in the year next following that in which
 the Agreement enters into force; and(b) in respect of other taxes on income, for 
 taxable
 years beginning on or after 1 January in the year next following that
 in which the Agreement enters into force.
Article 28
                  TERMINATION
This Agreement shall remain in force
                until terminated by a Contracting State. Either of [the] Contracting
                States may terminate the Agreement, through diplomatic channels, by
                giving written notice of termination on or before the thirtieth day of
                June of any calendar year following after the period of 5 years from
                the year in which the Agreement enters into force.
In such case, the Agreement shall
                cease
                to have effect:
| (a) | in respect of tax withheld at source, to | 
| (b) | in respect of other taxes on income, for | 
witness whereof the undersigned, being duly authorised thereto, have
signed this Agreement.
12th day of March 1999, in [the] Russian, Indonesian and English
languages in duplicate. All three texts are equally authentic. In case
of any divergence, the interpretation shall be given in accordance with
the English text.
| FOR THE GOVERNMENT OF |  FOR THE GOVERNMENT OF | 
