Article 15 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 of a comparable which is a resident of the other Contracting State may be taxed in that other Contracting State. Article l6 Artistes and Athletes 1．Notwithstanding the provisions of Articles l3 and l4，income derived by a resident of a Contracting State as an entertainer，such as theatre， motion Picture， radio or television artiste， or a musician ， or as an athlete， from his personal activities as such exercised in the other Contracting State，may be taxed in that other Contracting State ． 2．Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person， that income may， notwithstanding the provisions of Articles 7，13，and l4， be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised． 3．Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or athletes who are residents of a Contracting State from the activities exercised in the other Contracting State under a plan of cultural exchange between the Governments of both Contracting State shall be exempt from tax in that other Contracting State . Article 17 Pensions Subject to the Provisions of paragraph 2 of Article l8， pensions and other similar remuneration paid to a resident of a Contracting state in consideration of past employment shall be taxable only in that Contracting State． Article 18 Government Service 1．(a) Remuneration， other than a pension， paid by the Government of a Contracting State or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a local authority or organization thereof, in the discharge of the functions of a governmental nature, shall be taxable only in that State ． (b ) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other State who: 　　(i) is a national of that other State; or 　　(ii) did not become a resident of that other State solely for the purpose of rendering the services. 　　2.(a) Any pension paid by, or out of funds created by a Government of a Contracting State or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a local authority thereof shall be taxable only in that Contracting State. 　　(b ) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that other Contracting State. 　　3.The provisions of Articles 14, 15, 16, and 17 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by the Government of a Contracting State or a local authority thereof. 　　Article 19 Teachers and Researchers 　　An individual who is, or immediately before visiting a Contracting State was, a resident of the other Contracting State and is present in the first-mentioned State for the primary purpose of teaching , giving lectures or conducting research at a university, college, school or educational or scientific research institution recognized by the Government of the first-mentioned State shall be exempt from tax in the first-mentioned State, for a period of three years from the date of his first arrival in the first-mentioned State, in respect of remuneration for such teaching, lectures or research. 　　Article 20 Students and Trainees 　　1. A student, business apprentice or 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, shall be exempt from tax in that first- mentioned State on the following payments or income received or derived by him for the purpose of his maintenance, education or training: 　　(a) payments derived from sources outside that Contracting State for the purpose of his maintenance, education, study, research or training; 　　(b) grants, scholarships or awards supplied by the Government, or a scientific, educational, cultural or cultural organization where he is studying. 　　2. A student, business apprentice or trainee referred to in paragraph 1 shall, in respect of remuneration from employment, be entitled during his or her education or training to the same exemptions, relief or reductions in respect of taxes available to residents of the state which he or she is visiting. 　　Article 21 Other Income 　　1.tems of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State. 　　2.The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State , carries on business in the other Contracting State 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 income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 13, as the case may be, shall apply. 　　Article 22 Methods for the Elimination of Double Taxation 　　1.In Russia, double taxation shall be eliminated as follows: 　　Where a resident of Russia derives income from China the amount of tax on that income payable in China in accordance with the provisions of this Agreement, may be credited against the Russian tax imposed on that resident. The amount of credit ,however, shall not exceed the amount of the Russian tax on that income computed in accordance with the taxation laws and regulations of Russia. 　　2. In China, double taxation shall be eliminated as follows: 　　(a) Where a resident of China derived income from Russia the amount of tax on that income payable in Russia in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Chinese tat on that income computed in accordance with the taxation laws and regulations of China. 　　(b) Where the income derived from Russia is dividend paid by a company which is a resident of Russia to a company which is a resident of China and which owns not less than 10 percent of the shares of the company paying the dividend, the credit shall take into account the tax paid in Russia by the company paying the dividend in respect of its income. 　　Article 24 Non-discrimination 　　1.Nationals 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 nationals of that other Contracting State in the same circumstances are or may be subjected. The provisions of this paragraph shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting State. 　　2.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 Contracting State than the taxation levied on enterprises of that other State carrying on the same activities. The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 　　3.Except where the provisions of paragraph 8 of Article 7, paragraph 7 or Article 10, or paragraph 6 of Article 11 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall , for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned state. 　　4.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 firs-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. 　　Article 24 Mutual Agreement Procedure 　　1.Where a person considers that the actions of one or both of the Contracting State 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 national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 　　2.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 not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting State. 　　3.The competent authorities of the Contracting State shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application or the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement. 　　4.The competent authorities of the Contracting State may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the competent authorities of the Contracting State may meet together for an oral exchange of opinions. 　　Article 25 Exchange of Information 　　1.The competent authorities of the Contracting State shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting State concerning taxes covered by the Agreement, insofar as the taxation thereunder is not contrary to the Agreement, in particular for the prevention of 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 and 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 covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 　　2.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 the 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 public policy. 　　Article 26 Members of Diplomatic of Permanent Missions and Consular Officers 　　Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic or permanent missions and consular officers under the general rules of international law or under the provisions of special agreements. 　　Article 27 Entry Into Force 　　This Agreement shall enter into force on the thirtieth day after the date on which diplomatic notes indicating the completion of internal legal procedures necessary in each country for the entry into force of this Agreement have been exchanged. This Agreement shall have effect as respects income derived during the taxable years beginning on or after the first day of January next following that in which the Agreement enters into force. 　　Article 28 Termination 　　(a) This Agreement shall continue in effect indefinitely but either of the Contracting States may , on or before the thirtieth day of June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give written notice of termination to the other Contracting State through the diplomatic channel. In such event this Agreement shall cease to have effect as respects income derived during the taxable years beginning on or after the first day of January of the calendar year next following that in which the notice of termination is given. 　　DONE at Beijing on the 27th day of May 1994, in duplicate, in Chinese, Russian and English languages, all texts being equally authentic. In case of any divergence, the interpretation shall be made in accordance with the English text. For the Government of For the Government of The People's Republic of China the Russian Federation