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 Korea to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes article 1. 15. June 2008, in Džedž in the Republic of Latvia signed the Government and the Government of the Republic of Korea of the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Convention) and its 15 June 2008 in Džedž signed the Protocol (hereinafter referred to as the Protocol) with this law is adopted and approved. 2. article. Convention and the fulfilment of the obligations provided for in the Protocol are coordinated by the Ministry of finance. 3. article. The Convention and the Protocol shall enter into force in article 28 of the Convention within the time and in order, and the Ministry of Foreign Affairs shall notify the newspaper "journal". 4. article. The law shall enter into force on the day following its promulgation. With the law put the Convention and Protocol in English and Latvian. The law adopted by the Parliament in 2008 on December 18. President Zatlers in Riga, v. 30, 2008. in December, the Government of the Republic of LATVIA and the Government of the Republic of KOREA of the Convention on 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 Korea, the people's willingness to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed the following: article 1 persons covered this CONVENTION shall apply to persons Convention that is one or both of the Contracting State party to the country resident. Article 2 taxes covered by the CONVENTION (1) this Convention shall apply to taxes levied by the Contracting State or of its political or administrative unit of local government in good regardless of the method of collecting the tax. 2. income taxes 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, as well as taxes on capital appreciation. 3. The existing taxes to which this Convention applies, in particular, is: (a)) in Korea: (i) income tax; (ii) corporate tax; (iii) the special tax for rural development; and (iv) the tax on the population; (hereinafter Korean taxes); (b)): (i) corporate income tax; and (ii) the individual income tax; (hereinafter referred to as the Latvian tax). 4. this Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of this Convention is to supplement or replace the existing taxes. Both the competent authorities of the Contracting States inform each other of any significant changes in their respective taxation laws within a reasonable period of time, after it has been amended as follows. Article 3 General definitions 1. If it is not apparent from the context, otherwise in this Convention: (a)), the term "Korea" means the Republic of Korea, and, used in a geographical sense, it represents the territory of the Republic of Korea, including the territorial sea and any other Republic of Korea territorial sea adjacent territory, as territory that can be implemented in the Republic of Korea's sovereign rights or jurisdiction over waters, sea and Earth and natural resources contained therein; (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" mean depending on the context of Latvia or Korea; (d)), the term "tax" means depending on the context of Latvia or Korea; e) the term "person" means a natural person, company, or any other Association of persons; (f) the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association; g) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; h) the term "international traffic" means any carriage by sea or air vehicles by the company of a Contracting State, except for the cases when the sea or air vehicles move only in the other Contracting State; I) the term "competent authority" means: (i) Korea-Minister of finance and economy or its authorized representative; (ii) in Latvia, the Ministry of finance or its authorised representative; j) the term "national" means: (i) any natural person who has the nationality of a Contracting State; (ii) any legal person, partnership or association, whose status as the result of contracting in force in national legislation. 2. a Contracting State at any time pursuant to this Convention, all terms not defined therein shall have the meaning which they State Contracting laws at that time applied to the 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, main or principal business location, location management, place of incorporation (registration) or any other similar criteria, and also includes the State and any political or administrative units of 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. 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)) will be considered as the person only as a resident of the State in which they habitually resident; If you are habitually resident in two countries, this person will be considered only for residents 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, that person will be considered a resident of the country only, which is its usual home; c) if that person normally home in both countries or none of them, it will be considered only for residents of 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. If in accordance with this article, the provisions of part 1, a person other than a natural person, is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to resolve the matter by mutual agreement, taking into account that person's actual control location, main, or leading business location, place of incorporation (registration) or any other important factors. Article 5 permanent establishment 1. In this Convention, the term "permanent establishment" means a fixed place of business of which is wholly or partly carried on business. 2. The term "permanent establishment" includes: (a) the management of the company); b) branch; c) Office; (d) a factory;) e) workshop; and (f)) mine shaft, oil or gas extraction sites, quarries or any other place of extraction of natural resources. 3. A building site, a construction, Assembly or installation project or supervisory activities associated with them are considered permanent representation only if these works, projects or activities take longer 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) goods belonging to the company) or article items intended solely for storage, demonstration or delivery; (c) the goods belonging to the company) or article items 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 only to deal with a) to (e)) the actions referred to in points any combination thereof, if the combination of the action are generally preparatory or auxiliary character. 5. Notwithstanding paragraph 1 and the provisions of part 2, 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, with the exception If such a person is carried out only in part this article for steps that you perform certain actions in place, this particular site in accordance with the said part is not considered permanent representation. 6. It is considered that the company does not have permanent representation in the Contracting State where the undertaking is established in that country, using only the 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 in favour of the company is carried out and if the agent and the enterprise differ from the relations which should be established between independent persons, such agent shall not be considered an agent of an independent status within the meaning of this part. 7. the fact that the company is a resident of a Contracting State-controlled company, 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" have the meaning 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. Sea and air vehicles 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. the following article 1 and part 3 of the regulations apply also in relation to income from the company's real estate, as well as income from real property used for independent individual 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 representation of the existing 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 amount 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 expenses, including operational and general administrative expenses reasonably incurred as part of the permanent representation to the needs of the country or elsewhere, and which would be deductible if that permanent establishment were a separate Contracting State in which the permanent establishment, a company who pays those expenses, whether incurred in the State where the permanent establishment is situated or elsewhere. 4. 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. 5. 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. 6. 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 the sea or air the use of vehicles in international traffic are taxed only in the country. 2. in part 1 of this article, the rules 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 participating in the other Contracting State, the company's management or control or it 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 the company's management or control or they own 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 rules different from those provisions that the force between two independent companies , 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 in the other Contracting State, the cost of the 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 true owner of dividends is resident of the other Contracting State, the tax shall not exceed: a 5 per cent of the dividend) total, if real owner of dividends is a company (other than a partnership), which directly manages at least 25 percent of the company capital that paid dividends; 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 rights to participate in profits, not claims, as well as income from other rights, including corporate law, in accordance with the laws of the country in which the resident is a company that carries out the distribution of profits, is subject to the same taxation as income from the shares. 4. The parts 1 and 2 shall not apply if the rightful owner of dividends, 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 company-a 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 does it impose retained earnings tax, 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 also impose taxes according to relevant national laws in the Contracting State in which they arise, but, if the interest owner is implemented on the territory of the other Contracting State, a resident of the tax must not exceed 10 percent of the total amount of interest. 3. Notwithstanding the provisions of part 2 percent in one Contracting State and derives the other Contracting Government, including its political and administrative units, local authorities, Central Bank or any financial institution performing functions of public administration, or percent, gaining any resident of the other Contracting State in respect of claims, which is guaranteed by the other Contracting State Government , including its political and administrative units, local authorities, Central Bank or any financial institution performing public administration functions, will be exempt from taxation in the first country. 4. This article is part 3 of the application of the terms "the Central Bank and financial institution performing functions of public administration" means: (a)): (i) in Korea Korea's Bank; (ii) the Korea export-import bank; (iii) the Korea development bank; (iv) the Korea export insurance corporation; and (v) any other financial institutions that perform public administration functions, for which the correspondence way agreed between the competent authorities of the Contracting States; (b)): (i) the Bank of Latvia; and (ii) any other financial institutions that perform public administration functions, for which the correspondence way agreed between the competent authorities of the Contracting States. 5. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage and whether or not they have the right to participate in the debtor's profits, 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 income, which according to the provisions of article 10 are considered dividends. Interest received on payments made during, not be regarded as interest for the application of the provisions of this article. 6. This article part 1 and 2 shall not apply if the interest owner, which is implemented by the Contracting State resident, doing 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 there, and if the 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. 7. If the payer of the interest is a resident of a Contracting State, it is considered that the interest generated in this country. If, however, the person paying the interest, 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 fixed base, will be considered that the interest incurred in the State in which the permanent establishment or fixed base. 8. If, based on the special relationship between the payer and the interest percentage implemented owner 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 owner will, if implemented, 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 are levied according to each Contracting State laws and regulations, taking into consideration 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 national regulations of the Contracting State in which it arises, but if the true owner of the royalties is a resident of the other Contracting State, the tax shall not exceed: a 5 per cent of the royalties) the total volume of production, commercial, or scientific equipment, or the right to use them; and (b)) 10 percent of all other royalties total. 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 for radio and television broadcasting, any patent, trademark, 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. This article part 1 and 2 shall not apply if the rightful owner 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 permanent base, will be considered that the royalties arise in the country in which the permanent establishment or fixed base. 6. If, on the basis of the special relationship between the payer of royalties and royalties shall implement the owner 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 of royalties that would have been able to implement a single payer and the owner 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, you will be taxed according to each Contracting State laws and regulations, taking into consideration other provisions of this Convention. Article 13 capital gains 1. Capital gains, by a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real estate or shares of one company, which primarily consists of assets such as real estate taxing can in the other country. 2. 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, which created the independent personal services, including capital gains from such permanent missions (alone or with the whole enterprise) or of such a permanent disposal base disposal can impose taxes in the other Contracting State. 3. Capital gains by the public company, which uses the sea or air vehicles in international traffic, shall forfeit the use in international traffic, sea or air vehicles or disposes of the property, which belongs to the sea or air vehicles will be taxable only in that State. 4. Capital gains generated by the disposal of any property, other than that article 1, 2, and 3. the property referred to in part, taxes are imposed 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, providing professional services or other independent activities, taxes are imposed only in this country. This income may be subject to tax in the other Contracting State: a if the natural person) your operational needs using it regularly available permanent base in the other Contracting State but only to the extent that this income is attributable to this permanent base; (b) if the natural person) staying in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any twelve month period, but only part of the income it derives from that person in the other Contracting State actions. 2. The term "professional services" includes 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, 19 and 21 of the regulations, the payment of wages and other remuneration, similar to that of a resident of a Contracting State receives for gainful employment, taxes are imposed only in this country, 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 the consideration that 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 that the employer uses the second in the country. 3. Notwithstanding the previous paragraph of this article, the rules of remuneration received for paid work that is being done to a company of a Contracting State in international traffic used for sea or air vehicle, can impose taxes in the 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 of the supervisory organ, which is a member of the public in 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, as theatre, film, radio or television artist, musician, or as an athlete for his second State of the individual activities can impose taxes in the other country. 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. Notwithstanding paragraph 1 and the provisions of part 2, izpildītājmāksliniek or athlete who is a resident of a Contracting State, the income achieved in the other Contracting State of the transactions that occur under the special cultural exchange program agreed on by the two Governments of the Contracting States, tax in that other State shall be imposed. Article 18 pensions in accordance with article 19 of part 2 of the regulations for pensions and other similar remuneration, by a resident of a Contracting State receives for previous paid employment are taxable only in that State. Article 19 government service 1 a) for salaries, fees and other similar remuneration, other than a pension, and a natural person the cost of Contracting State or of its political or administrative unit of local government for this country, unit, or for the services provided to the municipality, the tax is only imposed on this country. (b) However, such salaries), fees and other similar remuneration for duties being imposed only in the other Contracting State if the services are rendered in that other 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) of the natural person the cost of Contracting State or of its political or administrative unit of local government or which are paid out of the funds set up for services provided by that person or entity for this country or municipality tax is only imposed on this country. (b) However, such pension tax) is charged only in the other Contracting State if the individual is a resident of the other State and national. 3.15, 16, 17, and article 18 shall apply to salaries, wages, other remuneration and pensions similar to that paid for services provided in respect of the Contracting State or of its political or administrative unit of local business. 4. This article is part 1 and 2 shall apply to remuneration or pensions are also paid to: (a)) in Korea: the Korean Bank, Korea export-import bank, Korea development bank, Korea export insurance corporation, the Korea Trade and investment promotion agency and other bodies performing public administrative functions and for which the competent authorities of the Contracting States have made in correspondence of the relevant agreement; (b)): the Bank of Latvia, Latvian development agency and other bodies performing public administrative functions and for which the competent authorities of the Contracting States have made in correspondence of the relevant agreement. 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 professors and teachers 1. Income, that of the teaching or research work shall receive physical person entering the Contracting State to teach or deal with the research work of the University, College, school or other similar public education this contracting authority, that the Government is recognized as a non-profit organization, and that person is, or immediately before the arrival of the State was the second Contracting State a resident of the are not taxable in the country in the first two years of the date when the person in the above purpose, the first came in the first State. 2. part 1 of this article shall not apply to income from research if such research is undertaken not in the public interest, but mostly of a specific person or persons personal gain. 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 of taxes are imposed only in that country. 2. part 1 of this article shall 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 of this Convention article 7 or 14. Article 23 avoidance of double taxation 1. in the case of the residents of Latvia, double taxation shall be avoided as follows: a where a resident of Latvia) derives income which, in accordance with the provisions of this Convention may impose taxes in Korea, and unless national legislation is more favourable provisions, reduce the resident's permit Latvia income tax on that portion of the tax is equal to the income tax paid in Korea. This reduction, 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 Korea; (b)) (a) (a) for the application of this paragraph, if the company) – resident of Latvia receives a dividend from a company-resident in Korea, in which it owns at least 10 percent of shares with full voting rights, the tax paid in Korea will include not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the profits of the company out of which the dividend was paid. 2. in the case of Korean resident of double taxation will be avoided as follows: according to Korean tax laws and provisions for any foreign country tax deduction from tax payable in Korea (without affecting the General principles); (a) where a resident of Korea) derive from the Latvian income which under the laws of Latvia and the Convention the regulations may impose taxes in Latvia, then the amount of the tax payable on that income in Latvia, permission to deduct from the tax payable by a resident of Korea. However, this amount of reduction shall not exceed the portion of the Korean tax as computed before this fall, and the application of which is attributable to the income which may be taxed taxes in Latvia; (b)) if income from dividends of Latvia, is that company-paid Latvian resident company-Korean resident who owns not less than 10 percent of all residents of Latvia public votes attaching to shares issued by, then the amount of the reduction should also include the tax that a company resident in Latvia has paid on the profits out of which the dividends are paid. 24. Article 1 of the prevention of DISCRIMINATION on the nationals of a Contracting State in the other Contracting State not subject to taxation or related requirements that are different or more burdensome than the taxation or the related requirements which, 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 are not party to one or both of the Contracting States of the residents. 2. For stateless persons – residents of a Contracting State in one of the Contracting States not subject to taxation or related requirements that are different or more burdensome than the taxation or the related requirements which, in the same circumstances, in particular with respect to residence, or can 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 8 or 6 of article 12, the provisions of part, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident, in determining the taxable profit of the company is to report by the same rules as if they are paid to a resident of the first mentioned 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 State 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. 25. Article 1 mutual consultation procedures. If a person believes that one or both of the Contracting State party to a national action in relation to 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's domestic legislation that remedies to submit complaints to the competent authority of the country of which the person is resident, or if the complaint relates to article 24, part 1 -the Contracting 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 of the domestic 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. If the agreement is appropriate for oral exchanges, such exchanges can take place with the competent authorities of the Contracting States of the representatives of the Commission. Article 26 exchange of information 1. The competent authorities of the Contracting States shall exchange the information necessary for the carrying out of the provisions of this Convention or national law requirements on the taxes to which this Convention applies, in so far as these regulations do not conflict with the provisions of this Convention. Article 1 of the Convention does not restrict the exchange of information. Any information received by a 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 authorities) involved in the tax to which this Convention applies, in the calculation of the collection, the use of coercive measures, trials or appeals related to these taxes. 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. 2. The provisions of part 1 should not be explained so that they bind the 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 technology, or to provide information, the disclosure of which would be contrary to the public interest (ordre public). Article 27 diplomatic and consular personnel, nothing in this Convention shall affect the diplomatic missions or consular posts personnel fiscal privileges which international law granted the General provisions or special agreements. Article 28 entry into force 1. Contracting Governments shall notify each other that the countries have met the constitutional requirements necessary for the entry into force of the Convention. 2. this Convention shall enter into force on the 15th day following that article referred to in the first subparagraph, the last statement date, and its provisions shall apply: (a)) in Korea: (i) in respect of withholding income taxes which costs time – starting with the tax amount payable on the first day of January or after the calendar year following the year in which the this Convention enters into force; (ii) for other taxes-starting with the tax year beginning January of the calendar year or after the first day of the calendar year following the year in which this Convention enters into force; (b)): (i) in respect of taxes withheld at the time the cost – starting with the income gained in January of the calendar year or after the first day of the calendar year following the year in which this Convention enters into force; (ii) in the case of other income taxes – starting with taxes payable in any tax year, which begins in January of the calendar year or after the first day of the calendar year following the year in which this Convention enters into force. Article 29 termination this Convention shall remain valid as long as the one Contracting State it shall be terminated. Each Contracting State may terminate this Convention, diplomatic channels by giving written notice of termination at least six months before any end of the calendar year after the period of five years following the entry into force of the Convention. In this case, the Convention will end: a) in Korea: (i) in respect of withholding income taxes which costs time – starting with the tax amount payable on the first day of January in the calendar year or after the following the year in which the notice of termination; (ii) in respect of other taxes, starting with the tax year beginning January of the calendar year or after the first day of the calendar year following the year in which the notice of termination; (b)): (i) in respect of taxes withheld at the time the cost-starting with the income gained in January of the calendar year or after the first day at calendar year following the year in which the notice of termination; (ii) in the case of other income taxes – starting with taxes payable in any tax year, which begins in January of the calendar year or after the first day of the calendar year following the year in which the notice of termination. In witness thereof, the undersigned, being duly authorized their Governments, have signed this Convention. The Convention is drawn up in duplicate in Džedž 15 June 2008, Latvian, Korean and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.

The Republic of Latvia, the Republic of Korea on behalf of the Government of the Government of the Mansi Emanuel Slakter Kang of the Government of the Republic of Latvia and the Government of the Republic of KOREA to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income signed the PROTOCOL of the Government of the Republic of Latvia and the Government of the Republic of Korea to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Convention), the parties have agreed upon the following provisions, that is an integral part of the Convention. Concerning article 1 it is understood that the Convention shall not apply to any society, trust or other entity that is a resident of a Contracting State and who is a beneficial owner of one or more persons who are not residents of this State, or controlled, directly or indirectly, by one or more persons not resident in that State, if the tax imposed on corporations, trusts or other entities (income after When account is taken of anyone and in any form that company, trust or other entity, or any other person the applicable tax reduction or relief, including tax, investment, or discount) is significantly lower than the amount of the tax imposed by that State, depending on the circumstances, if all shares of the company's share capital, or trust or other unit in every part of the beneficial owner should have one or more physical persons that is a resident of that State. However, this part does not apply if 90 percent or more of the income that is subject to the lowest tax are completely made from this company, trust or other entity active business that is not a passive income from investments. With regard to article 6 and 13 it is understood that all income and capital gains that accrued from article 6 of the said immovable property situated in the Contracting State, seizures, taxes may be imposed in the Contracting State in accordance with the provisions of article 13. In witness thereof, the undersigned, being duly authorized their Governments, have signed this Protocol. The Protocol is drawn up in two copies in the Džedž 15 June 2008, Latvian, Korean and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.

The Republic of Latvia, the Republic of Korea on behalf of the Government of the Government of the Mansi Emanuel Slakter Kang on CONVENTION BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the REPUBLIC OF Korea 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 Korea 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 PERSONS COVERED 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, as well as taxes on capital appreciation. 3. The existing taxes to which the Convention shall apply in particular to: (a)) in Korea: (i) the income tax; (ii) the corporation tax; (iii) the special tax for rural development; and (iv) the inhabitan tax; (hereinafter referred to as "Korean tax"); (b)) in the United Kingdom: (i) the enterprise income tax (income tax of enterprises); and (ii) the personal income tax (will tax revenue); (hereinafter referred to as "Latvian tax"). 4. The Convention shall apply also to any identical or substantially similar taxes which 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 which have been made in their taxation laws of respectiv within a reasonable period of time after such changes. Article 3 GENERAL DEFINITION 1. For the purpose of this Convention, unless the context otherwise requires: a the term) "Korea" means the Republic of Korea, and when used in a geo-graphical sense, means the territory of the Republic of Korea, including its territorial sea, and any other area adjacent to the territorial sea of the Republic of Korea as an area within which the sovereign rights or jurisdiction of the Republic of Korea with respect to the waters , the sea-bed and subsoil, and their natural resources may be exercised; (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 subsoil and their natural resources; (c)) the terms "a Contracting State" and "the other Contracting State" mean Latvia or Korea, as the context requires; (d) the term "tax") means Latvian tax or Korean tax, as the context requires; e the term "person") includes an individual, a company and any other body of persons; (f) the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose; (g)) the terms "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; h) 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; I) the term "competent authority" means: (i) in Korea, the Minister of finance and Economy or his authorized representative; (ii) in Latvia, the Ministry of finance or its authorised representative; (j) the term "national") means: (i) any individual possessing the nationality of a Contracting State; (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 head or main office, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or 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. 2. Where by reason of the provision of paragraph 1 of this article 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 of this article a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour: the it settle the questions by mutual agreement having regard to its place of effective management, the place of change or head office, place of incorporation, or any other relevant factor. Article 5 permanent establishment 1. For the purpose of 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 extraction of natural resources. 3. A building site, a construction, assembly or installation project or a supervisory activity connected therewith 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 of this article, where a person-other than an agent of an independent status to whom paragraph 6 of this article 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 of this article 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. How-ever, when the activities of such an agent are exercised wholly or almost wholly on behalf of that enterprise and where the conditions between the agent and the enterprise differ from those which would be made between independent persons, such agent shall 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 of this article shall apply to income derived from the direct use, letting, or use in any other form of immovabl property. 4. The provision of paragraphs 1 and 3 of this article 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 business 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 business 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 of this article, 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 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 a reasonable allocation of Executive and general administrative expense of so incurred) and which would be deductibl if the permanent establishment were an independent entity which paid those expense incurred in the whethers of Contracting State in which the permanent establishment is situated or elsewher. 4. 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. 5. 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. 6. 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. The provision of paragraph 1 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) 12:5 per cent) of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividend; 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 rights, including 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 of this article 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. The 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 exceeds 100 10 per cent of the gross amount of the interest. 3. Notwithstanding the provision of paragraph 2 of this article, interest arising in a Contracting State and derived by the Government of the other Contracting State including political subdivisions and local authorities thereof, the Central Bank of that other State or any financial institution performing functions of a governmental nature or by any resident of the other Contracting State with respect to debt-claim guaranteed by the Government of that other State including political subdivisions and local authorities thereof the Central Bank of that other State or any financial institution performing functions of a governmental nature shall be main from tax in the first-mentioned State. 4. For the purpose of paragraph 3 of this article, the terms "the Central Bank and financial institution performing functions of a governmental nature" mean: a) in the case of Korea: (i) the Bank of Korea; (ii) the Korea export-import Bank; (iii) the Korea Development Bank; (iv) the Korea export Insurance Corporation; and (v) such other financial institution performing functions of a governmental nature as may be specified and agreed upon in letters exchanged between the competent authorities of the Contracting to States; (b)) in the case of Latvia: (i) the Bank of Latvia; and (ii) such other financial institution performing functions of a governmental nature as may be specified and agreed upon in letters exchanged between the competent authorities of the Contracting to States. 5. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage, and whethers or not carrying a right to participat in the debtor's profits, 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. 6. The provision of paragraphs 1 and 2 of this article 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. 7. 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. 8. 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) 12) 5 percent of the gross amount of the paid for the USA to royalt of industrial , commercial or scientific equipment; b) 10 percent 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 for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or 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 of this article 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 a 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 CAPITAL gains 1. 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 or shares in a company the assets of which mainly of such property be consis may be taxed in that other State. 2. 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. 3. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic 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. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3 of this article, shall be only in the taxabl 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 only in the taxabl Contracting State a. But such income may be taxed also in the other Contracting State: a if he has a fixed) base regularly available to him in the other Contracting State for the purpose of performing his activities; but only so much of the income as is attributabl to that fixed base; (b) if his stay) in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the in any twelve month period; in that case, only so much of the income as is derived from his activities performed during the period of his presence in that other Contracting State. 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, 19, and 21, 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 of this article, 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. Article 16 directors ' fees directors ' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board 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. Notwithstanding the provision of paragraph 1 and 2 of this article, income derived by an entertainer or sportsmen who are residents of a Contracting State from the activities exercised in the other Contracting State under a special programme of cultural exchange agreed upon between the Governments of both Contracting States, shall be the main tax in the other State from you. Article 18 PENSION 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. Article 19 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or 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 or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or 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, 17, 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 or a political subdivision or a local authority thereof. 4. The provision of paragraphs 1 and 2 of this article shall apply in respect of the likewis remuneration or pension paid by: a) In the case of Korea: the Bank of Korea, the Korea export-import Bank, the Korea Development Bank, the Korea export Insurance Corporation, the Korea Trade-Investment Promotion Agency and other institutions performing functions of a governmental nature as may be specified and agreed upon in letters exchanged between the competent authorities of the Contracting to States; (b)) In the case of Latvia: the Bank of Latvia, the Latvian Development Agency and other institutions performing functions of a governmental nature as may be specified and agreed upon in letters exchanged between the competent authorities of the Contracting to States. 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 PROFESSOR AND teachers 1. An individual who visits a Contracting State generally for the purpose of teaching or carrying out research at a university, College, school or other similar educational institutions recognised as non profit organization by the Government of that Contracting State and who is or was immediately before that visit a resident of the other Contracting State shall be exempted from taxation in the first-mentioned Contracting State on remuneration for such teaching or research for a period not exceeding two years from the date of his first visit for that purpose. 2. The provision of paragraph 1 of this article shall not apply to income from research which is undertaken not for public interest but primarily for the private benefit of a specific person or persons. 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 of this article 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 the case of a resident of Latvia, double taxation shall be avoided as follows: (a)) where a resident of Latvia's income which, deriv in accordanc with this Convention, may be taxed in Korea, 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 Korea. 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 Korea. (b)) For the purpose of sub-paragraph (a)), where a company that is a resident of Latvia receive a dividend from a company that is a resident of Korea in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Korea shall include not only the tax paid on the dividend, but also the appropriate portions of the tax paid on the underlying profits of the company out of which the dividend was paid. 2. In the case of a resident of Korea, double taxation shall be avoided as follows: subject to the provision of Korean tax law regarding the allowance as a credit against Korean tax of tax payable in any country other than Korea (which shall not be the general principles of the affec thereof); (a)) where a resident of Korea's income from deriv Corporation which may be taxed in the United States under the law of Latvia in accordanc with the provision of this Convention, in respect of that income, the amount of tax payable shall be Latvian allowed as a credit against the tax imposed on the Korean payable are resident. The amount of the credit shall not, However, on the 12nd of Korean tax as a computed before the credit is given, which is appropriate to that income; (b)) where the income derived from Latvia is a dividend paid by a company which is a resident of Latvia to a company which is a resident of Korea which own not less than 10 per cent of the total shares issued by that company, the credit shall take into account the Latvian tax payable by the company in respect of the profits out of which such dividend is paid. 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, in particular with circumstanc respect their residence, may be subjected to or. 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 8 of article 11, or paragraph 6 of article 12, apply, interest, and other disbursement royalt paid by an 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. 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, for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisabl in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting to States. Article 26 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is not cessary for carrying out the provision of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by article 1. Any information received 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 , or the determination of appeal in relations to, the taxes covered by the Convention. 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. 2. In no case shall the provision of of paragraph 1 of this article 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). 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 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 fifteenth day after the date of the later of the notifications referred to in paragraph 1 of this article and it is a provision shall have effect: (a)) in Korea: (i) in respect of taxes withheld at source, for non payable on or after the first day of January in the calendar year following the first that in which this Convention enter into force; and (ii) in respect of other taxes, for the year beginning on or after taxabl the first day of January in the calendar year following the first that in which this Convention enter into force; (b)) in the United Kingdom: (i) 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; (ii) 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 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 from the fifth year following that in which the Convention entered into force. In such event, the Convention shall cease to the have effect: (a)) in Korea: (i) in respect of taxes withheld at source, for non payable on or after the first day of January in the calendar year following the first that in which the notice is given; and (ii) in respect of other taxes, for the year beginning on or after taxabl the first day of January in the calendar year following the first that in which the notice is given; (b)) in the United Kingdom: (i) 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; (ii) 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 year next following the year in which the notice has been given. In witness whereof, the undersigned, duly authorised by the by the Governments of their respectiv theret, have signed this Convention. Done in duplicate at Jeju this 15 day of June 2008, in the Latvian, Korean 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 For the Government of the Republic of Latvia to the Republic of Korea At the I-a Kang soo Slakter PROTOCOL TO the CONVENTION BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the REPUBLIC OF Korea FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income At the signing of the Convention between the Government of the Republic of Latvia and the Government of the Republic of Korea for the avoidance of double taxation and prevention of fiscal evasion the with respect to taxes on income (hereinafter referred to as "the Convention"), the undersigned have agreed upon the following provision which shall form an integral part of the United Nations Convention. 1. With reference to article 1 It is understood that the Convention shall not apply to any company or other entity, trust that is a resident of a Contracting State and beneficially owned or controlled, directly the ISO or indirectly, by one or more persons who are not residents of that State, if the amount of the tax imposed on the income of the company trust or other entity, by that State (after taking into account any reduction or offset of the amount of tax in any manner, including a refund, credit, contributions, reimbursemen or allowance to the company, trust, or other entity or to any other person) is substantially lower than the amount that would be imposed by that State if all of the shares of the capital stock of the company or all of the interests in the trust or other entity , as the case may be, were owned by or beneficially one more individual who were residents of that State. However, this paragraph shall not apply if 90 per cent or more of the income on which the lower amount of tax is imposed is derived exclusively from the active conduct of a trade or business carried on by it, other than passive income from the investment business. 2. With reference to article 6 and article 13 It is understood that all income and gains from the alienation of property referred to immovabl in article 6 and situated in a Contracting State may be taxed in that Contracting State in accordanc with the provision of article 13. In witness whereof, the undersigned, duly authorised by the by the Governments of their respectiv theret, have signed this Protocol. Done in duplicate at Jeju this 15 day of June 2008, in the Latvian, Korean 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 For the Government of the Republic of Latvia to the Republic of Korea At the I-a Kang soo Slakter