Article 22 LIMITATION OF BENEFITS

1. Where this Agreement provides (with or without other conditions) that income from sources in the Russian Federation shall be exempt from tax, or taxed at the reduced rate, in the Russian Federation and under the laws in force in Singapore the said income is subject to tax by reference to the amount thereof which is remitted to or received in Singapore and not by reference to the full amount thereof, then the exemption or reduction of tax to be allowed under this Agreement in the Russian Federation shall apply only to so much of the income as is remitted to or received in Singapore.

2. This Agreement shall not apply to any person who became a person covered by the Agreement if the principal goal of such a person is to enjoy the benefits of any reduction in or exemption from tax provided by this Agreement. In no case shall this exclusion apply to any person engaged in real business activity. The competent authorities of the Contracting States shall consult each other on the application of this provision.