МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

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 State in the
same  circumstances,  in  particular with respect to residence, are or
may be subjected.
     2.  The taxation on a permanent establishment which an enterprise
of a Contracting State has in the other Contracting State shall not be
less  favorably levied in that other State than the taxation levied on
enterprises  of that other State carrying on the same activities. This
provision  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 1 of Article 9,
paragraph  7  of  Article  11,  or  paragraph  7 of Article 12, apply,
interest,   royalties,   fees   for  technical  assistance  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. Similarly, any debts of an enterprise of a
Contracting  State to a resident of the other Contracting State shall,
for the purpose of determining the taxable capital of such enterprise,
be deductible under the same conditions as if they had been contracted
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  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.