Article 23 METHODS OF ELIMINATION OF DOUBLE TAXATION

1. In Russia:

Where a resident of Russia derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, the amount of tax on that income payable in Singapore shall be credited against the tax imposed in Russia. The amount of credit, however, shall not exceed the amount of the tax on that income computed in accordance with the laws and regulations in Russia.

2. In Singapore:

Where a resident of Singapore derives income which, in accordance with the provisions of this Agreement, may be taxed in Russia, the amount of tax on that income payable in Russia shall be credited against the tax imposed in Singapore. The amount of credit, however, shall not exceed the amount of the tax on that income computed in accordance with the laws and regulations in Singapore. Where such income is a dividend paid by a company which is a resident of Russia to a resident of Singapore owning directly or indirectly not less than 10 per cent of the share capital of the first-mentioned company, the credit shall take into account the Russian tax paid by that company on the portion of its profits out of which the dividend is paid.

3. For the purpose of this Article the term "Russian tax" shall be deemed to include the amount of Russian tax which, under the laws of the Russian Federation and in accordance with this Agreement, would have been paid but was not paid according to the Russian laws which provide special incentive measures-designed to promote economic development and foreign investments in the Russian Federation. This provision shall apply for the first five years for which the Agreement is effective, but the competent authorities of the Contracting States may consult each other to determine whether this period shall be extended.