Dividends
3. The term "dividends" as used in this article means income from shares or other rights, not being debt claims, entitling the holder to a share in profits, as well as incomes - even if paid in the form of interest - which are subject to taxation in the same way as income from shares according to the tax legislation of the state where the company paying the dividends has its place of permanent residence. This term also includes any payments made on units of mutual funds or similar collective investment schemes (excluding those mentioned in paragraph 5 of article 6 "Income from real property" of the Agreement).
The term "shares" as used in this article includes depositary receipts for these shares.
Source: Protocol amending the Agreement between the Russian Federation and the Grand Duchy of Luxembourg on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and property