The Government Of The Republic Of Latvia And The Government Of The Republic Of Cyprus Of The Convention For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income

Original Language Title: Par Latvijas Republikas valdības un Kipras Republikas valdības konvenciju par nodokļu dubultās uzlikšanas un nodokļu nemaksāšanas novēršanu attiecībā uz ienākuma nodokļiem

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Read the untranslated law here: https://www.vestnesis.lv/op/2016/202.1


The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Government of the Republic of Cyprus of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes article 1. 24 may 2016 signed in Brussels in the Government of the Republic of Latvia and the Government of the Republic of Cyprus, the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Convention) with this law is accepted and approved. 2. article. Fulfilment of the obligations provided for in the Convention are coordinated by the Ministry of finance. 3. article. The Convention shall enter into force on the 28th for the period specified in article and in order, and the Ministry of Foreign Affairs shall notify the official Edition of the "journal". 4. article. The law shall enter into force on the day following its promulgation. To put the Convention by law Latvian and English. The Parliament adopted the law in 2016 on October 6. The President r. vējonis 2016 in Riga on October 18, the Government of the Republic of LATVIA and the Government of the Republic of Cyprus, the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income the Government of the Republic of Latvia and the Government of the Republic of Cyprus, the desire to enter into people's Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows. Article 1 scope of application this Convention shall apply to persons who have one or both of the Contracting States residents. Article 2 taxes covered by the CONVENTION (1) this Convention shall apply to taxes on income imposed by the Contracting State or of its political or administrative units of local government, regardless of the method of collecting the tax. 2. income taxes deemed all taxes imposed on total income or on the part of income, including taxes on the capital gains of the movable or immovable property seizures. 3. The existing taxes to which the Convention shall apply are: a in particular) Cyprus: (i) the income tax; (ii) the corporate income tax; (iii) national defence special contributions; (iv) the capital gains tax (hereinafter referred to as "Cypriot tax"); (b)): (i) corporate income tax; (ii) the individual income tax; (hereinafter referred to as "Latvian tax"). 4. the Convention shall apply also to any identical or substantially similar taxes which, supplementing or replacing the existing taxes are introduced after the date on which the Convention is closed for signature. The competent authorities of the Contracting States inform each other of any substantial amendments made to the national tax legislation. Article 3 General definitions 1. If the context does not otherwise specified, then this risk‐adjusted Convention: a) the term "Cyprus" means the Republic of Cyprus and, used in a geographical sense, includes the national territory, the territorial sea, and any area outside the territorial sea, including areas adjacent to it, the exclusive economic zone and the continental shelf, in accordance with the laws of Cyprus and in accordance with international law has been or may be established as the area where Cyprus can exercise their sovereign rights or jurisdiction; (b)), the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the laws of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (c) the terms "a Contracting State)" and "the other Contracting State", depending on the context, the meaning of Latvia or Cyprus; (d)) the term "person" means a natural person, company, or any other Association of persons; e the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association; (f) the terms ") of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; (g)) the term "international traffic" means any transport by a ship or aircraft by an enterprise of a Contracting State, except when the ship or aircraft is moving only in the other Contracting State; h) the term "competent authority" means: (i) in Cyprus, the Minister of finance or his authorised representative; (ii) in Latvia, the Ministry of finance or its authorised representative; I) the term "national" means: (i) any natural person who has the nationality of a Contracting State; and (ii) any legal person, partnership or association, whose status as the result of contracting in force in national legislation. 2. as regards the application of the Convention in any Contracting State shall, for all the undefined terms has the meaning to them at the time, the country's laws and regulations relating to taxes covered by the Convention, unless the context is otherwise, and the risk‐adjusted State the relevant tax legislation meaning prevails over other laws of this state the intended meaning. Article 4 resident 1. In this Convention, the term "resident of a Contracting State" means any person who, under the laws of this country are taxed based on their place of residence, residence, location management, the creation of the site, or any other similar criteria, and also includes the State, any of its political and administrative entity or any local government. However, this term does not include those individuals in that State taxes are imposed only in respect of their income from this country to the existing sources of profit or the capital. 2. Where, in accordance with the provisions of part 1 an individual is a resident of both Contracting States, its status would be as follows: (a) the person is considered to be) only for residents of the country in which they are habitually resident; If you are habitually resident in two countries, this person shall be deemed to be a resident only of the State, with which it has closer personal and economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it is not a permanent residence in one of the two countries, this person is considered a resident of the country only, which is its usual home; c) if that person normally home in both countries or is not one of them, it is considered to be the only resident in the country, which is a national of that person; (d)) if that person is a national of both States or no, the national competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, in accordance with the provisions of part 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to resolve the matter by mutual agreement and determine the procedure for the application of the Convention to that person. Article 5 permanent establishment

1. In this Convention, the term "permanent establishment" means a fixed place of business of the company, which is wholly or partly carried on business. 2. The term "permanent establishment" includes mainly: (a)) control location; b) branch; c) Office; (d) a factory;) e) workshop; and (f)) mine shaft, oil or gas extraction sites, quarries or any other natural resource exploration or mining site. 3. A building site, a construction, Assembly or installation project or a supervisory or related advisory activities are considered a permanent establishment only if these works, project or activity occurs for more than nine months. 4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall not include: (a) the use of buildings and equipment) only and exclusively the goods belonging to, or for the storage of the products demonstrated or supplies; (b)) or of the goods belonging to the product items that are intended solely for storage, demonstration or delivery; (c)) or of the goods belonging to the inventory of products intended exclusively for processing in the other company. (d) the specific site) designed exclusively for the purchase of goods or products to your company's needs or the collection of information for the company's needs; e) specific action site intended solely to carry out the business of any other preparatory or ancillary activities; f) specific action site intended solely to make a) to (e)) the transactions referred to in points in any combination, if the combination of the action are generally preparatory or auxiliary character. 5. Notwithstanding paragraph 1 and 2 of the regulations, if a person who is not referred to in part 6 status of independent agent, running your business, and it has empowered the State to enter into contracts on behalf of the company, and it constantly uses this power, then in all activities carried out by such person for your business, it is considered that the company has a permanent establishment in the country concerned, unless such person has carried out only part 4 actions foreseen in the that perform certain actions in place, the place of action under the said part is not considered permanent representation. 6. It is considered that the company does not have a permanent establishment in a Contracting State solely because the company carries on business in that State through a broker, agent or any other agent of an independent status, provided that such persons perform their normal business activities. However, if such an agent is completely or almost completely business is carried out, he is not considered an independent agent status in this part in that sense. 7. The fact that the company-a resident of a Contracting State, controlled by the society, which is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking in itself does not mean that any of these companies is the second permanent representation of society. Article 6 INCOME from real property 1. income which a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State taxes. 2. The term "immovable property" shall have the meaning which it has its laws and regulations of a Contracting State in which the property concerned is located. In any case, this term covers property which belongs to real estate property, livestock and equipment used in agriculture and forestry, rights to which the land property law general rules, any rights to use the opportunity to buy real estate or similar right to acquire immovable property, real property and rights to variable or fixed payments as consideration for the mineral deposits, natural ore and other natural resources, or the right to use them. Vessels and aircraft are not considered real estate. 3. the provisions of part 1 apply to the income from immovable property directly, letting or use in any other way. 4. parts 1 and 3 terms also apply in relation to income from the company's real estate, as well as income from real property used for independent personal services. Article 7 business profits 1. Contracting State company profits are taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment there. If the enterprise carries on business in that way, the company's profits may impose taxes in the other country, but only to the profit, which can be attributed to the permanent establishment. 2. in accordance with the provisions of part 3, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit margins, as it would if it had been separated and independent company that performs the same or similar business activities under the same or similar conditions and independently carry out transactions with the company that it is a permanent establishment. 3. in determining the profits of the permanent representation are allowed to deduct the expenses incurred for the purposes of the standing representative offices located in the country or elsewhere, including operational and general administrative costs. Editions, which allows you to deduct the Contracting State may include only expenses that are deductible in accordance with its national laws and regulations. 4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between its divisions, part 2 does not prohibit Contracting State as usual after this principle, determine the profit for tax purposes; However, the method of distribution must be such that the result matches the principles contained in this article. 5. On the permanent representation of the profits not only because it has purchased the goods or products for the company, which is the permanent representation. 6. for the purposes of applying the provisions of the preceding paragraph, the profits attributed to the permanent establishment shall be determined each year by the same method, except if there is sufficient reason to do otherwise. 7. If the profit is included in the other articles of this Convention see income separately, this article shall not affect the other provisions of this article. Article 8 shipping and air TRANSPORT 1. Contracting State company profits gained from ships or aircraft in international traffic, the use of taxable only in that State. 2. the application of this article, profits from the use of ships in international traffic include profits from: (a)), hiring hiring them (or trip) completely; (b)) irregular vessel leasing, hiring them without crew and supply. 3. the Contracting State company profits from the use of containers, maintenance or lease (including trailers, barges and related equipment for the transport of containers) used in international traffic, is taxed only in the country. 4. The provisions of this article shall also apply to profits from the participation in a pool, joint business or international traffic transport agency. Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participate in the company of the other Contracting State, in the controls or owns part of the company's capital, or b) the same persons directly or indirectly participating in the enterprise of a Contracting State in the other Contracting State and enterprise management, controls or owns part of the company's capital, and in any of these cases, these two companies in commercial or financial relations are created or established by the rules different from those provisions that the force between two independent enterprises, then any profits which would, but for one of the companies affected by the above provisions did not have, can be included in the company's profits, and it may be appropriate to impose taxes. 2. where a Contracting State includes in the profits of an enterprise of that State and taxes accordingly profits on it, in respect of which no other country in the other Contracting State, the company has been taxed, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, the other country take appropriate adjustment for the size of the tax What are the gains of the other country. In determining this adjustment, take into consideration other provisions of this Convention and, if necessary, the competent authorities of the Contracting States for consultations. Article 10 dividends

1. Dividends company-a resident of a Contracting State, the cost of the other Contracting State, a resident may be taxed in that other State taxes. 2. However, such dividends may also impose taxes under the national laws of the Contracting State of which the resident is a company that pays dividends, but if this the real beneficiary of the dividends is a resident of the other Contracting State, the tax shall not exceed: (a) the percentage of the dividend) 0 total, if it true beneficiary is a company (other than a partnership); b) 10 per cent of the total dividends in all other cases. This part shall not affect the taxation of company profits from which dividends. 3. The term "dividends" in this article means income from shares, or other debt obligations not resulting from the right to participate in company profits, as well as income from other corporate rights which, in accordance with the laws of the State of which the resident is a company that performs the distribution of profits, subject to the same taxation treatment as income from shares. 4. parts 1 and 2 shall not apply if the payment of the actual beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State of which the dividends is resident in the firm's costly using existing permanent representation there, or give independent personal services in the other State through a permanent base located there, and where participation, which is paid out in dividends, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the company-resident of a Contracting State derives profits or income, in the other Contracting State, that other State may not impose any taxes or these companies paid dividends, except where the dividends are paid to a resident of the other State, or if the participation of which is paid out in dividends, is actually related to the permanent representation or permanent base in another country, nor to impose a tax on the profit for the whole of society even If the dividends paid or retained earnings consists in whole or in part from the other country of profit or income. Article 11 interest 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes. 2. However, such interest may be taxed taxes according to relevant national laws in the Contracting State in which they arise, but if this the real beneficiaries of the interest is a resident of the other Contracting State, the tax shall not exceed: (a) the percentage of interest) 0 total, where interest paid to a company which is a resident of a Contracting State in the other Contracting State, a resident of the public (other than a partnership), and it is the interest of the beneficiary; b) 10 per cent of the total interest in all other cases. 3. Notwithstanding the provisions of part 2, interest arising in a Contracting State if it has and is the real beneficiary is the Government of the other Contracting State, a political or administrative units of local governments, the central bank or any financial institution wholly owned by that Government, or interest that is paid on Government, political and administrative entity or municipal guaranteed loans, are exempt from taxation in the first country. 4. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes, which belong to these securities, bonds or debentures. The term "interest" does not include any income which, in accordance with the provisions of article 10 are treated as dividends. The application of the provisions of this article, interest received on time payments, are not considered interest. 5.1, 2 and 3 shall not apply if the interest the real beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located therein, and of claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 6. If the payer of the interest is a resident of a Contracting State, it is considered that the interest generated in this country. However, if the person who paid the interest, regardless of whether that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which incurred debt obligations, on which the interest is paid, and if such interest is paid (bear) permanent establishment or a permanent basis, it is considered that this interest arises in the State in which the permanent establishment or fixed base. 7. If, on the basis of the special relationship between the payer of the interest and the interest of the true beneficiary, or between both of them and some other person, the amount of interest that relate to debt claims, for which it is paid, exceeds the amount that would have been able to agree to the interest payer and the interest of the beneficiary, if they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the payment of the part which exceeds this amount, taxes imposed on each of the national legislation in the light of the other provisions of this Convention. Article 12 royalties 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes. 2. However, such royalties may also impose taxes according to relevant national laws and regulations of the Contracting State in which they occur, but if the real beneficiary of the royalties is a resident of the other Contracting State, the tax shall not exceed: (a) the percentage of the royalties) 0 total royalties paid, if the Contracting State in the other Contracting State of the society to the public (other than a partnership), and is the true beneficiary of the royalties; b) 5 percent of the total of the royalties in all other cases. 3. The term "royalties" in this article means payments of any kind received as a compensation for the use of any copyright or rights to use any copyright on literary, artistic or scientific work, including cinematograph films and films or recordings and other image or sound reproduction means the radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the production , commercial or scientific equipment, or for the right to use them, or for information concerning industrial, commercial or scientific experience. 4. parts 1 and 2 shall not apply if the real beneficiary of the royalties, which is a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located there, and if the right or property for which the royalties are paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the payer of the royalties is a resident of a Contracting State, it is considered that the image occurs in the country. If, however, the person paying the royalties, whether or not that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, due to which a duty to pay the royalties, and if the payment of the royalties (bear) the Permanent Mission or a permanent basis, it is considered that the royalties arise in the State in which the permanent establishment or fixed base. 6. If, on the basis of the special relationship between the payer and the true beneficiaries or between both of them and some other person, the amount of the royalties relating to the use, right or information for which it is paid, exceeds the amount that would have been able to single payer and the beneficiary, if they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the portion of the payment that exceeds this amount, is taxed in accordance with the national laws and regulations, taking into consideration other provisions of this Convention. Article 13 alienation of property

1. the Income or capital gains which a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real property, may be subject to taxes in the other country. 2. Capital gains, by a resident of a Contracting State derives disposes of shares or comparable interests in more than 50 per cent of their value directly or indirectly from the other Contracting State of an existing property, may be taxed in that other State taxes. 3. Capital gains that accrued, disposing of property, which is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State, or disposing of property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, established independent personal services, including capital gains from the alienation of such a permanent representation (alone or with the whole enterprise) or of such a disposal of the standing base can impose taxes in the other country. 4. Capital gains, by the Contracting Government Enterprise disposal the use in international traffic of ships or aircraft or property that belongs to such ships or aircraft, are taxable only in that State. 5. Capital gains from the alienation of any property other than 1, 2, 3 and 4, the property is taxable only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. resident of a Contracting State – physical persons income gained from providing professional services or other independent activities are taxable only in the country, except if that person needs their activities using it regularly available permanent base the second Contracting State. If you are using such a permanent base, the income may be subject to taxes for the second Contracting State but only to the extent that it is applicable to this permanent base. The application of this article, if a resident of a Contracting State – physical person, resident in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxation year, it is considered that the person uses it regularly available permanent base in the other State and the income that accrued on the second country made the above actions are applied to this permanent base. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as doctors, lawyers, engineers, architects, dentists and accountants of independent operation. Article 15 dependent personal services 1.16, 18 and article 19 rules for payment of wages and other similar remuneration, by a resident of a Contracting State receives for gainful employment are taxable only in that State unless paid work is not performed in the other Contracting State. If the salaried work is performed in the other Contracting State, the remuneration received for it can impose taxes in the other country. 2. Notwithstanding the provisions of part 1, remuneration which a resident of a Contracting State receives for paid work that is performed in the other Contracting State, be taxable only in the first mentioned State if: (a) the beneficiary) is found in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxation year; and (b) the remuneration is paid) an employer who is not a resident of the other State, or the name of the employer; and (c) the remuneration is not paid) (bear) permanent representation or permanent base, used by the employer in the other country. 3. Notwithstanding the preceding provisions of this article, remuneration received for paid work that is being done to a company of a Contracting State in international traffic used the ship or aircraft, can impose taxes only in this country, except that the remuneration accruing to residents of the other Contracting State, in which case it may impose taxes in the other country. Article 16 DIRECTORS ' fees directors ' fees and other similar payments received by a resident of a Contracting State as the Board of directors or any other similar organ of a company that is a member of the other Contracting State, a resident may be taxed in that other State taxes. Article 17 artists and athletes 1. articles 14 and 15 of the regulations to the income of a resident of a Contracting State as izpildītājmāksliniek, such as a theatre, film, radio or television artist, or a musician, or as an athlete for your individual activities in the other Contracting State may be taxed in that other State taxes. 2. If izpildītājmāksliniek or athlete's income on his individual activity in the area in question is paid rather than izpildītājmāksliniek or athlete himself but to another person, to the following income regardless of the 7, 14 and 15 the provisions of article 1 may be subject to taxes in the Contracting State in which the activity or sports izpildītājmāksliniek. 3. parts 1 and 2 of the rules are not applied to the income that izpildītājmāksliniek or athlete has learned about the activities performed in the Contracting State, if the visit to that State is supported wholly or mainly from one or both of the Contracting States, or their political or administrative units of the local public finances. In this case, the income shall be taxable only in the Contracting State of which the resident is izpildītājmāksliniek, or athlete. Article 18 pensions 1. in accordance with article 19 of the rules of part 2 of the pensions paid and other similar remuneration paid to a resident of a Contracting State on the previous paid employment are taxable only in that State. 2. Notwithstanding the provisions of part 1, the pensions paid and other benefits, both periodic and lump-sum payments, which are paid out in accordance with national social security laws and regulations, or under any other Contracting State to create a national social welfare system is taxed only in the country. Article 19 government service 1 a) for salaries, fees and other similar remuneration, other than a pension and paid by the natural person contracting State or of its political or administrative unit of local government for that State or entity or municipality services are taxable only in that State. (b) However, such salaries), fees and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely to provide these services. 2. (a) to any pension to which) natural person the cost of Contracting State or of its political or administrative unit of local government, or who is paid from the funds set up for services provided by that person or entity for this country or municipality, is taxed only in the country. (b) However, such pension shall be) taxable only in the other Contracting State if the individual is a resident of the other State and national. 3.15, 16 and article 18 shall apply to salaries, wages, and other similar remuneration paid to a pension in respect of services rendered in connection with a Contracting State or of its political or administrative unit of local business. Article 20 students payments which a residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State and who was the first resident in that country have come only for the purpose of study or internship, in this country are not taxed if such payments are from sources that are not in the country. Article 21 offshore ACTIVITIES zone

1. The provisions of this article shall apply irrespective of the Convention article 5 to 20. 2. the Person – resident of a Contracting State relating to the activities of the other Contracting State the sea and subsoils and there existing natural resource exploration and exploitation of the other Contracting State, ice area, in accordance with this article and the provisions of part 4 will be considered business carried out in the other Contracting State through a permanent representation of the existing there. 3. part 2 of this article shall not apply if the mentioned action is for a period or periods not exceeding in the aggregate 30 days in any twelve month period commencing or ending in the taxation year. However, the needs of this part: (a)), a person is associated with another person, be deemed to be the person to take action, if this action is essentially the same as its first performed by that person; (b)) a person shall be deemed to be associated with another person if one of them directly or indirectly controls the other or a third person or third party directly or indirectly controls both of the above mentioned persons. 4. profit, received by a resident of a Contracting State for supplies or transport to staff or between areas in the other Contracting State which is open to the sea and subsoils and there existing natural resource exploration and exploitation related activities, or on the tugboat and other services, which take place in addition to this transaction will be taxed only in the first country. 5. a) in accordance with this part, the provisions of point b) salaries, wages and other similar remuneration received by a resident of a Contracting State for work related to the other Contracting State the sea and subsoils, and keep the existing natural resource exploration and exploitation, may be taxed in that other Contracting State to the extent that work has been done in this country to the other shelf area. However, such a payment is taxed only in the first country where the work is carried out in the area of the shelf, the employer who is not a resident of the other State, provided that the work is carried out for a period or periods not exceeding in the aggregate 30 days in any twelve month period commencing or ending in the taxation year; (b)), pay wages and other similar remuneration received by a resident of a Contracting State of the work carried out on board a ship or aircraft, or supplying services to the staff or between places in the other Contracting State which is open to the sea and subsoils and there existing natural resource exploration and exploitation activities related to the work of the tugs or other vessels providing services in addition to the above activities can be subject to tax in the Contracting State of which the resident is a person who performs the following steps. 6. income which a resident of a Contracting State alienates a benefit: (a)) or use the right to study; or (b)) property, which hosted the second Contracting State and used in connection with the other national and subsoils and there existing natural resource exploration and exploitation; or (c)), which shares your values or values most directly or indirectly derived from the above rights or property, or the rights and property of the set can taxing in that other country. In this part, the term "research and right of use" means the right to property, which may be generated by the other Contracting State the sea and subsoils and there existing natural resource exploration and exploitation, including the right to participation in the ownership or profit, you can get this property. Article 22 other income 1. Other income of a resident of a Contracting State which are not specified in the preceding articles of the present Convention, irrespective of their sources are taxable only in that State. 2. the provisions of part 1 does not apply to income, other than income from article 6 defined in part 2 of the real property, if the income beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation of the existing there, or give independent personal services in the other State through a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. Article 23 avoidance of double taxation 1. Cyprus double taxation is resolved as follows. Under Cyprus legislation the tax rules for foreign tax paid off the taxes payable in Cyprus that is paid on any income that is earned in Latvia, will be allowed to reduce the tax paid in Latvia, which is paid in accordance with the laws of Latvia and the provisions of this Convention. However, this tax included must not exceed the part of Cyprus which is calculated before including the application of the tax in respect of the following income types. 2. In Latvia, double taxation is avoided as follows. Where a resident of Latvia derives income which, in accordance with this Convention may impose taxes in Cyprus, then, unless national legislation is more favourable provisions, reduce the resident's permit Latvia income tax for an amount equal to the income tax paid in Cyprus. These reductions must not, however, exceed that part of the income tax, which is calculated in Latvia before and where the application of this reduction is attributable to the income which may be taxed taxes in Cyprus. 24. Article 1 of the prevention of DISCRIMINATION on the nationals of a Contracting State in the other Contracting State shall not apply to the taxation and related requirements that are different or more burdensome than the taxation or the related requirements in the same circumstances, in particular in the context of residence applies or may apply to the nationals of the other. This provision shall, notwithstanding the provisions of article 1, also apply to persons who do not have one or both of the Contracting States residents. 2. For stateless persons – residents of a Contracting State, any of the Contracting States shall not apply to the taxation and related requirements that are different or more burdensome than the taxation and related requirements that apply under the same conditions or may be applied to nationals of the country concerned. 3. Taxation the company of a Contracting State to the permanent representation the other Contracting State may not be less favourable than those of other taxation public companies which perform the same operation. This provision should not be interpreted that it imposes on the Contracting State the obligation to grant the other Contracting State any personal relief to residents, discount and reduction in relation to taxation, which this country give its residents, in the light of their civil status or family responsibilities. 4. Except where the applicable part 1 of article 9, article 11 part 7 or article 12 part 6 rules, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident by establishing this company's taxable profit must be deducted subject to the same provisions as if they were to be paid to the first residents of that State. Similarly, the enterprise of a Contracting State, any debts other Contracting State, a resident of establishing this company's taxable capital, is to be deducted in the same terms as if it refers to the first residents of that State. 5. the Contracting State whose capital, in whole or in part, directly or indirectly, belongs to one or more residents of the other Contracting State or in full or in part, directly or indirectly control these residents, the first in that country may not be subject to any taxation or any requirements associated with it, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or which is more burdensome for them. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind and name. Article 25 conciliation procedure between the

1. If a person believes that one or both of the Contracting States concerning this person causes or will cause the taxation which does not comply with the provisions of this Convention, that person may, irrespective of the country in national legislation that remedies, to submit complaints to the competent authority of the country of which that person is resident, or if the complaint relates to article 24, part 1 of the Member State whose competent authority national is that person. The complaint shall be submitted for review within three years of the first notification of the action which led to the provisions of this Convention do not appropriate taxation. 2. If the competent authority deems the complaint to be justified and even fail to reach a satisfactory solution, it will endeavour to agree with the other competent authority of a Contracting State to this Convention shall not prevent the adequate taxation. Any such agreement is reached is due irrespective of the Contracting State's national laws and the established time limits. 3. the national competent authorities should seek mutual agreement resolve any difficulties or eliminate doubts which may arise out of the interpretation or application of this Convention. They may also consult to avoid double taxation in cases not provided for in the Convention. 4. in order to reach agreement on these issues in the preceding subparagraph, the competent authorities of the Contracting States may communicate directly with one another, as well as through a joint Commission consisting of them or their representatives. Article 26 exchange of information 1. Contracting States must be made to the competent authorities information that is expected in the important application of the provisions of this Convention or the national administration of the laws or enforcement for all the type and name of the duties imposed on a Contracting State or a political or administrative units of local government, insofar as such taxation is not contrary to the Convention. 1 and 2, of the Convention article does not limit the exchange of information.
2. Any information in accordance with the format set out in part 1, the receiving Contracting State, should be considered as sensitive as information that is obtained in accordance with the laws of this State and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the above part 1 tax calculation, withholding, or in appeals in the investigation, or the aforementioned monitoring. Such persons or authorities, this information must be used only for the purposes mentioned above. They may disclose the information in public hearings or in judgements. 3. in any event, parts 1 and 2 shall not be interpreted in such a manner that they impose a Contracting State the obligation: a to carry out administrative measures), which does not comply with one or other of the contracting national legislation and administrative practice; (b)) to provide information that is not available under one or the other national legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or process a transaction, or to provide information, the disclosure of which would be contrary to public policy (ordre public). 4. If a Contracting State in accordance with this article shall be required to provide the information to the other Contracting State should use its information gathering measures to obtain the requested information, even if it is considered that the information requested in the other country would not need their taxation requirements. The obligation referred to in the preceding sentence is subject to the restrictions of part 3, but in no case shall such limitations may not explain that these Contracting State permits decline to provide information solely because it has no national interests with regard to this information. 5. in no case shall the provisions of paragraph 3 are not to be interpreted as meaning that they permit the Contracting State refuse to supply information solely because the information is the holder of a bank, another financial institution, agent, or person acting on the authorisation or trust, or because it relates to ownership of the second person. Article 27 diplomatic missions and consular personnel the provisions of this Convention shall not affect the diplomatic missions or consular posts personnel fiscal privileges which it applied in accordance with international law, the General rules or specific agreement terms. Article 28 entry into force 1. Contracting Governments through diplomatic channels in writing notify each other that the constitutional requirements have been met, in order to give effect to this Convention. 2. this Convention shall enter into force with this article in part 1 of this last statement date and its provisions in both Contracting States shall apply: (a)) in respect of taxes withheld at the time the cost-income accruing on the first day of January or after the calendar year following the year in which the Convention enters into force; (b)) in the case of other income taxes-taxes payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the Convention enters into force. Article 29 termination This Convention is in force for the duration of the Contracting State of its activities shall be terminated. Each Contracting State may terminate the Convention, through diplomatic channels, by giving written notice of termination at least six months before any end of the calendar year. In this case the Convention in both Contracting States shall cease: (a)) in respect of taxes withheld at the time the cost-income accruing on the first day of January or after the calendar year following the year in which the notice is given; (b)) in the case of other income taxes-taxes payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the notice is given. In witness thereof, the undersigned, being duly authorised, have signed this Convention.
Drawn up in Brussels in duplicate in 24 may 2016, every Latvian, Greek, and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.
The Government of the Republic of Latvia, the Republic of Cyprus Government, Finance Minister Dana Reizniec-oak Finance Minister Harris of the Georgiad CONVENTION BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the REPUBLIC OF Cyprus FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income the Government of the Republic of Latvia and the Government of the Republic of Cyprus To conclud a Convention (menu Rngton Line4), for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows: article 1 PERSONAL scope this Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2 taxes COVERED 1. This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespectiv of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovabl property. 3. The existing taxes to which the Convention shall apply in particular to: (a)) in Cyprus: (i) the income tax; (ii) the corporate income tax; (iii) special contributions for the defence of the Republic; (iv) the capital gains tax; (hereinafter referred to as "Cyprus tax"); (b)) in the United Kingdom: (i) the enterprise income tax; (ii) the personal income tax; (hereinafter referred to as "Latvian tax"). 4. The Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify the other of any each significant changes that have been made in their taxation laws. Article 3 GENERAL DEFINITION of

1. For the purpose of this Convention, unless the context otherwise requires: a the term) "Cyprus" means the Republic of Cyprus and, when used in a location sense, includes the national territory, the territorial sea thereof as well as any area outside the territorial sea, including the contiguo area, the exclusive economic zone and the continental shelf, which has been or may hereafter be designated , under the laws of Cyprus and in accordanc with international law as an area within which Cyprus may exercise sovereign rights or jurisdiction; (b)) the term "United States" means the Republic of Latvia and, when used in the sense of location, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the law of Latvia and in accordanc with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub soil and their-natural resources; (c)) the terms "a Contracting State" and "the other Contracting State" mean Latvia or Cyprus, as the context requires; (d) the term "person") includes an individual, a company and any other body of persons; e the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose; (f) the term ") enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; h) the term "competent authority" means: (i) in Cyprus, the Minister of finance or his authorised representative; (ii) in Latvia, the Ministry of finance or its authorised representative; (I) the term "national") means: (i) any individual possessing the citizenship of a Contracting State; and (ii) any legal person, partnership or association deriving its status as such from the law in force in a Contracting State. 2. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purpose of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State. Article 4 resident 1. For the purpose of this Convention, the term "resident of a Contracting State" means any person who, under the law of that State, is liabl to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision, any local authority thereof. This term, however, does not include any person who is liabl to tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provision of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests); (b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to the in order to settle the question by mutual agreement and determin the mode of application of the Convention to such person. Article 5 permanent establishment 1. For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a a place of management); (b)) a branch; c) an Office; (d) a factory;) e) a workshop; and f a mine, an oil) or gas well, a quarry or any other place of exploration or extraction of natural resources. 3. A building site, a construction, assembly or installation project or a supervisory activity connected therewith or consultancy constitut a permanent establishment only if such site, project or activity lasts for a period of more than nine months. 4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other. Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of general law respecting landed property apply, any option or similar right to the immovabl property, usufruc acquir of immovabl property and rights to variable or fixed payments as considerations for the working of, or the right to work , mineral deposits, sources and other natural resources. Ships and aircraft shall not be regarded as immovabl property. 3. The provision of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovabl property. 4. The provision of paragraphs l and 3 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits

1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as a deduction in "of which the expense incurred for the purpose of the permanent establishment, including Executive and general administrative expense so incurred, whethers of in the State in which the permanent establishment is situated or elsewher. The expense to be allowed as deduction in "by a Contracting State shall include only expense the are under the domestic law of deductibl of that State. 4. Insofar as it has been customary in a Contracting State to determin the profits to be attributed to a permanent establishment on the basis of an apportionmen of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclud that Contracting State from determining the profits to be taxed by such an apportionmen as may be customary; the method of apportionmen, however, the adopted shall be such that the result shall be in accordanc with the principles led in this article. 5. From the profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which the deal with separately in other articles of this Convention, then the provision of those articles shall not be affected by the provision of this article. Article 8 SHIPPING AND AIR transport 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxabl only in that State. 2. For the purpose of this article from the profits of ship operations in international traffic include profits from: a) the rental of ships on a full (time or voyage) basis; (b)) the occasional rental of ships on a bare-boat basis. 3. Profits of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers and related equipment, used for the transport of containers) used in international traffic shall be the taxabl only in that State. 4. The provision of this article shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Article 9 ASSOCIATED enterprises 1. Where (a) an enterprise of a Contracting) State of directly or indirectly participat in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons directly or indirectly the participat in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State , and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State-and taxes accordingly-profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises , then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provision of this Convention and the competent authorities of the Contracting States shall if the cessary not consult each other. Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not: (a) exceeds 100 0 per cent) of the gross amount of the dividends if the beneficial owner is a company (other than a partnership); b) 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall not be affec the taxation of the company in respect of the profits out of which the dividend is paid with. 3. The term "dividends" as used in this article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State or of deriv profits income from the other Contracting State, that other State may not impost any tax on the dividends paid by the company, except insofar as such dividends to be paid to a resident of that other State or insofar as the holding in respect of which the dividend is paid is effectively connected with a permanent establishment or a fixed base situated in the a to get other State , nor subject the company's undistributed profits to a ' tax on the company's undistributed profits, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State. Article 11 interest

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it «arise and according to the law of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not: (a) exceeds 100 0 per cent) of the gross amount of the interest, if the interest is paid by a company that is a resident of a Contracting State to a company (other than a partnership) that is a resident of the other Contracting State and is the beneficial owner of the interest; b) 10 per cent of the gross amount of the interest in all other cases. 3. Notwithstanding the provision of paragraph 2, interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including political subdivisions and local authorities thereof, the Central Bank or any financial institution wholly owned by that Government, or interest paid in respect of a loan guaranteed by that Government or authority, shall be, in the main subdivision from tax in the first-mentioned State. 4. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage, and in particular, income from government securities and income from bonds or debentur, including premium and prizes attaching to such securities, bonds or debentur. The term "interest" shall not include any income which is treated as a dividend under the provision of article 10. Penalty charges for late payment shall not be regarded as interest for the purpose of this article. 5. The provision of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this Convention. Article 12 to 1 to ROYALT Royalt arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may be taxed in royalt also in the Contracting State in which they «arise and according to the law of that State, but if the beneficial owner of the royalt to is a resident of the other Contracting State, the tax so charged shall not: (a) exceeds 100 0 per cent) of the gross amount of the stay, if the royalt royalt with paid by a company that is a resident of a Contracting State to a company (other than a partnership) that is a resident of the other Contracting State and is the beneficial owner of the royalt; (b) 5 per cent) of the gross amount of the stay in all other cases royalt. 3. The term "royalt" as used in this article means payments of any kind received as a considerations for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes and other means of image or sound reproduction for radio or television broadcasting, any patent, trade mark, design or model , plan, secret formula or process, for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, having regard to the use, right or information for which they are paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this Convention. Article 13 ALIENATION OF PROPERTY 1. Income or gains derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of shares or interests of any kind in comparabl in a company or other entity deriving more than 50 per cent of their value directly or indirectly from immovabl property situated in the other Contracting State may be taxed in that other State. 3. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services , including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 4. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be only in the taxabl you state. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxabl only in the Contracting State of which the alienator is a resident. Article 14 independent PERSONAL services 1-income derived by an individual. who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxabl only in that State unless he has a fixed base regularly available to him-in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributabl to that fixed base. For this purpose, where an individual who is a resident of a Contracting State stay in the other State for a period or Contracting period exceeding in the aggregate 183 days in any twelve-month period in commencing or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to above that are performed in that other State shall be attributabl to that fixed base. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Article 15 dependent PERSONAL services

1. Subject to the provision of articles 16, 18 and 19, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by), or on behalf of, an employer who is not a resident of the other State; and c the remuneration is not) borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provision of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, shall be only in the taxabl you state, except in the case where the remuneration is derived by a resident of the other Contracting State, in which case it may also be taxed in that other State. Article 16 directors ' fees directors fees ' and others similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. Article 17 artistes AND SPORTSMEN 1. Notwithstanding the provision of articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman's, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsman's in his capacity as such notes to the accru entertainer or sportsman's himself but to another person, that income may, notwithstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman's are exercised. 3. The provision of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsman's if the visit to that State is wholly or mainly supported by public funds of one or both of the Contracting States, political subdivisions or local authorities thereof. In such case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident. Article 18 PENSION 1. Subject to the provision of paragraph 2 of article 19, and other similar remuneration paid pension to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. 2. Notwithstanding the provision of paragraph 1, the pension paid and others benefits, or periodic compensation, whethers waded sum awarded under the social security legislation of a Contracting State or under any public scheme organised by a Contracting State for social welfare purpose shall be of the taxabl only in that State. Article 19 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State, a political subdivision or a local authority thereof to an individual in respect of services rendered to that State, political subdivision or authority shall be only in the taxabl you state. (b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State, a political subdivision or a local authority thereof to an individual in respect of services rendered to that State, political subdivision or authority shall be only in the taxabl you state. (b) However, such pension shall be) taxabl only in the other Contracting State if the individual is a resident of, and a national of, that State. 3. The provision of articles 15, 16 and 18 shall apply to salar, and other similar remuneration, WAGs and their pension, in respect of services rendered in connection with a business carried on by a Contracting State, a political subdivision or a local authority thereof. Article 20 students payments which a student, an apprentice or a 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 receive for the purpose of his maintenance, education or training shall not be taxed in that State , provided that such payments «arise from sources outside that State. Article 21 offshore activities 1. The provision of this article shall apply notwithstanding the provision of Article 5 of the 20 of this Convention. 2. A person who is a resident of a Contracting State and carr to one activities offshore in the other Contracting State in connection with the exploration or exploitation of the seabed or subsoil or their natural resources situated in that other State shall, subject to paragraphs 3 and 4 of this article, be deemed in relations to those activities to be carrying on business in that other State through a permanent establishment situated therein or fixed base. 3. The provision of paragraph 2 shall not apply where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in any twelve month period commencing or ending in the fiscal year concerned. However, for the purpose of this paragraph: a activities carried on by) a person who is associated with another person shall be regarded as carried on by the other person if the activities in question are substantially the same as those carried on by the first-mentioned person; (b) a person shall be deemed) to be associated with another person if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or third persons. 4. Profits derived by a person who is a resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed or subsoil or their natural resources are being carried on in a Contracting State, or from the operation of a vessel for the tugboat and others auxiliary to such activities , shall be only in the taxabl you state. 5. (a) subject to sub-paragraph) (b) of this paragraph), salar, WAGs and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the seabed or subsoil or their natural resources situated in the other Contracting State may, to the the exten that the duties are performed offshore in that other State , be taxed in that other State. However, such remuneration shall be taxabl only in the first-mentioned State if the employment is carried on offshore for an employer who is not a resident of the other State and provided that the employment is carried on for a period or periods not exceeding in the aggregate 30 days in any twelve month period commencing or ending in-the fiscal year concerned. (b)), WAGs and Salar similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between or from locations, where activities connected with the exploration or exploitation of the seabed or subsoil or their natural resources are being carried on in the other Contracting State , or in respect of an employment exercised aboard a tugboat or other vessel will operated auxiliary to such activities, may be taxed in the State of which the person carrying on such activities is a resident. 6. Gains derived by a resident of a Contracting State from the alienation of: (a) exploration or exploitation rights;) or b property situated in the other) Contracting State and used in connection with the exploration or exploitation of the seabed or subsoil or their natural resources situated in that other State; or c shares deriving their value) or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together may be taxed in that other State. In this paragraph "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the seabed or subsoil or their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets. Article 22 OTHER income

1. Items of income of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Convention shall be only in the taxabl you state. 2. The provision of paragraph 1 shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform 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 provision of article 7 or article 14, as the case may be, shall apply. Article 23 ELIMINATION OF double TAXATION 1. In Cyprus double taxation shall be eliminated as follows: subject to the provision of Cyprus Tax Law regarding credit for foreign tax, there shall be allowed as a credit against tax payable in respect to Cyprus of any item of income derived from Latvia the Latvian tax paid under the law of Latvia and in accordanc with this Convention. The credit shall not, however, that about 12 of the Cyprus tax, as computed before the credit is given, which is appropriate to such items of income. 2. In Latvia the double taxation shall be eliminated as follows: where a resident of Latvia's income which, deriv in accordanc with this Convention, may be taxed in Cyprus, unless a more favourabl treatment is provided in its domestic law, Latvia shall allow as a deduction in "from the tax on the income of that resident, an amount equal to the income tax paid thereon in Cyprus. Such notes shall, however, exceeds 100 Marbles that part of the income tax in Latvia as computed before the deduction in "is given, which is attributabl, to the income which may be taxed in Cyprus. 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 burdensom than the taxation and connected requirements to which nationals of that other State in the same, in particular with circumstanc respect their residence, may be subjected to or. This provision shall, notwithstanding the provision of article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. a person who with Stateles of residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensom than the taxation and connected requirements to which nationals of the State concerned in the same circumstanc with or may be subjected. 3. 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 State than the taxation levied on enterprises of the 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 allowance, relief and reduction for taxation purpose on account of civil status or family responsibilities which it grants to its own residents. 4. Except where the provision of paragraph 1 of article 9, paragraph 7 of article 11, or paragraph 6 of article 12, apply, interest, and other disbursement royalt paid by enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxabl profits of such enterprise, be-deductibl under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debt of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the capital of the taxabl such enterprise, be-deductibl under the same conditions as if they had been contracted to a resident of the first-mentioned State. 5. 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 burdensom than the taxation and connected requirements to which other similar enterprises of the first-mentioned State may be subjected to or. 6. The provision of this article shall, notwithstanding the provision of article 2, apply to taxes of every kind and description. Article 25 MUTUAL agreement procedure 1-where a person consider. that the actions of one or both of the Contracting States result or will result for him in taxation not in accordanc with the provision of this Convention, he may, irrespectiv 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 24, 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 accordanc with the provision of the Convention. 2. The competent authority shall endeavour, if the objection to it appear 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 which is not in accordanc with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any doubt arising as to the difficult or is it the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 4. The competent authorities of the Contracting States the may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. Article 26 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is foreseeably relevant for carrying out the provision of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by articles 1 and 2. Any information received under paragraph 2 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of , the enforcement or prosecution in respect of, the determination of the appeal in relations to the taxes referred to in paragraph 1, or the oversigh of the above. Such persons or authorities shall use the information only for such purpose. They may be published by the information in disclos court proceedings or in judicial decisions. 3. In no case shall the provision of of paragraphs 1 and 2 be construed so as to impost on a Contracting State the obligation: a to carry out administrative) measure the at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not) obtainabl is 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 disclos) any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordanc with this article, the other Contracting State shall use its information gathering "to obtain the requested information, even though that other State may not need such information for its own tax purpose. The obligation in the preceding line led is subject to the limitations of paragraph 3 but in no case shall such limitations from be construed to permit a Contracting State to supply information to declin solely because it has from the domestic interest in such information. 5. In no case shall the provision of of paragraph 3 be construed to permit a Contracting State to supply information solely to declin because the information is held by a bank, other financial institution, or a person acting in nomine an agency or a fiduciary capacity or because it relate to ownership interests in a person. Article 27 members OF DIPLOMATIC missions AND CONSULAR posts Nothing in this Convention shall be affec the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provision of special agreements. Article 28 ENTRY into force

1. The Governments of the Contracting States shall notify each other in writing through diplomatic channels when the constitutional requirements for the entry into force of this Convention have been complied with. 2. The Convention shall enter into force on the date of the later of the notifications referred to in paragraph 1 and its provision shall have effect in both Contracting States: a in a) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the Convention enter into force; (b)) in respect of other taxes on income, for taxes for any fiscal year beginning chargeabl on or after the first day of January in the calendar year next following the year in which the Convention enter into force. Article 29 TERMINATION this Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year. In such event, the Convention shall cease to the have effect in both Contracting States: a in respect of taxes) withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (b)) in respect of other taxes on income, for taxes for any fiscal year beginning chargeabl or after the first day of January in the calendar year next following the year in which the notice has been given. In witness whereof, the undersigned, duly authorised the theret, have signed this Convention. Done in duplicate at Brussels this 24th day of May 2016, in the Latvian, Greek and English languages, all three texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.
For the Government of the Republic of Latvia For the Government of the Republic of Cyprus Dana Reizniec-Minister of finance oak Harris the Georgiad Minister of finance