The Saeima has adopted and the President promulgated the following laws: For the Republic of Latvia and the Kingdom of Morocco, of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes article 1. July 24, 2008 in Riga, Republic of Latvia signed and Convention of the Kingdom of Morocco for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Convention) with this law is accepted and approved. 2. article. Fulfilment of the obligations provided for in the Convention are coordinated by the Ministry of finance. 3. article. The Convention shall enter into force on the 29th for the period specified in article 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. To put the Convention by law Latvian and English. The Parliament adopted Act of 13 November 2008. President Valdis Zatlers in Riga V. on 27 November 2008 the Republic of LATVIA and the Kingdom of MOROCCO 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 Kingdom of Morocco, people's willingness to promote and strengthen the economic relations, concluding the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed the following: 1. the article of the PERSON Covered by the Convention, this Convention shall apply to persons who have one or both of the Contracting States residents. Article 2 taxes covered by the CONVENTION (1) this Convention shall apply to taxes that are imposed on the Contracting State or of its political or administrative unit of local government in good apart from this taxation. 2. income taxes deemed all taxes imposed on total income, that income or part, including taxes, which are levied income from 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)): (i) corporate income tax; and (ii) the individual income tax; (hereinafter referred to as the Latvian tax); b) Morocco: (i) the income tax; and (ii) the corporation tax; (hereinafter referred to as Moroccan tax). 4. This Convention shall apply also to any identical or substantially similar taxes which, supplementing or replacing the existing taxes will be introduced after the date of signature of this Convention. The competent authorities of the Contracting States inform each other of any significant amendments to this country in the relevant tax legislation. Article 3 General definitions 1. If the context does not otherwise specified, then this risk‐adjusted Convention: a) the terms "Contracting State" and "the other Contracting State" mean, depending on context or Latvia Morocco; (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 term "Morocco" means the Kingdom of Morocco, and, used in a geographical sense, the term "Morocco" includes: (i) the territory of the Kingdom of Morocco, the territorial sea; and (ii) the territorial sea of the adjacent marine areas, the land and sea depths (continental shelf) and the special economic zone for which Morocco in accordance with its domestic laws and international law, exercise sovereign rights with respect to natural resource exploration and exploitation; (d)), the term "taxation" means depending on the context of Latvia or Morocco; e) the term "person" means a natural person, company, or any other Association of persons, including partnerships; (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 means of transport carried out by the company, which is the actual place of management is located in a Contracting State, as defined in article 4, part 3, except for the cases when the sea or air transport to move only in the other Contracting State; I) the term "competent authority" means: (i) in Latvia – the Ministry of finance or its authorised representative; (ii) in Morocco: the Minister of finance or his 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 it not defined terms shall have the meaning they have at the time of the relevant Contracting State laws relating to taxes covered by the Convention, unless the context is otherwise, and the risk‐adjusted State the relevant tax legislation meaning prevails over other laws of this state the intended meaning. Article 4 resident 1. In this Convention, the term "resident of a Contracting State" means any person who, under the laws of this country are taxed based on their place of residence, residence, location management, place of incorporation 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 (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. Where, in accordance with the provisions of part 1, a person other than a natural person is resident of both Contracting States, then this person will be considered a resident of the State in which its place of effective management. In this Convention, it is considered that person's actual place of management is located in the Contracting State in which its principal and registered office of the company. Article 5 permanent establishment 1. In this Convention, the term "permanent establishment" means a fixed place of business of the company, which is wholly or partly carried on business. 2. The term "permanent establishment" includes: (a) the management of the company); b) branch; c) Office; (d) a factory;) e) workshop; f) mine shaft, oil or gas extraction sites, quarries or any other natural resource exploration and extraction; g) point of sale; and (h)), which is passed to the warehouse, the person that provides storage services to other people. 3. The term "permanent establishment" also includes: a a building site, construction), Assembly or installation project or supervisory activities associated with them, but only if these works, projects or activities take longer than six months; (b)) the provision of services, including consultancy services, by an enterprise through employees or employ other staff, the company attracted for this purpose, but only if this type of activity (for the same or a connected project) the Contracting State continues for a period or periods exceeding in the aggregate three months in any twelve month period; c) Contracting State the actions related to this country's existing maritime and subsoils and there existing natural resource exploration and exploitation, if the duration of such an operation as a whole exceeds the period or periods of 30 days in any twelve month period; (d)) that Contracting State provides services, facility, or equipment and machinery leasing, used mineral deposits of geological reconnaissance, extraction or use in this country, if such activity generally exceed the duration of the period or periods of 30 days in any twelve month period. 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 solely to deal with (a) to (e))) the following, in any combination thereof, if the combination of the action are generally preparatory or auxiliary character. 5. Notwithstanding paragraph 1 and 2 of the regulations, if a person who is not referred to in part 6 status of independent agent, running your business, and it has empowered the State to enter into contracts on behalf of the company, and it constantly uses this power, then in all activities carried out by such person for your business, it is considered that the company has a permanent establishment in the country concerned, unless such person has carried out only part 4 actions foreseen in the that perform certain actions in place, the place of action under the said part is not considered permanent representation. 6. Will be considered that the Contracting State does not have a permanent establishment in the other Contracting State if the company is doing business in this 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 business is conducted, and if the commercial and financial relations between the company and the agent is different from the relations which should be established between independent parties, he will 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 rights in respect of immovable property, real property and rights to variable or fixed payments as consideration for the mineral deposits, natural ore and other natural resources, or the right to use them. Vessels, barges and aircraft transport means will not be considered real estate. 3. the provisions of part 1 shall be applied in respect of income from real estate direct use, letting or use in any other way. 4. If the company or any other entity, incorporated under the laws of a Contracting State, or other law (including corporate law) gives its owner the right to these companies or other entities use of immovable property, the income from these rights, letting or use in any other way may impose taxes to the Contracting State in which the immovable property is situated. 5.1, 3, and part 4 of the rules will be applied also with regard to the income from immovable property of the company, as well as income from real property used for independent individual services. Article 7 business profits 1. Contracting State company profits will be 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. However, the profit gained by the sale of goods or products that are the same or similar to the goods or products that are sold through the permanent representation, or profit that is being made about the other business that is the same or is similar to what is done through permanent representations, can be considered to be attributable to the permanent representations, if it is established that sale or business have been organized in such a way as to avoid paying taxes in the country in which the permanent establishment is situated. 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 a permanent representation, will be allowed to deduct the expenses incurred for the purposes of the standing representative offices located in the country or elsewhere, including operational and general administrative costs. However, such a deduction is not allowed for payments (other than the actual expenditure), the cost of the permanent representation of the main undertaking, or any other Office of the company as royalties, fees or other similar payments for patents or other rights, or as a Commission on management or for special services, or, except in the case where the company is a bank, as interest on the sums of money that is loaned to the permanent representation of. Also, establishing permanent representation in profits, will not be taken into account in an amount (other than the actual expenditure), permanent representation from the main company or other it Office. 4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between its divisions, part 2 does not prohibit Contracting State as usual after this principle to determine the profit for tax purposes; However, the method of distribution must be such that the result matches the principles contained in this article. 5. On the permanent representation will not be applied the earnings just because it has purchased the goods or products for the company, which is the permanent representation. 6. for the purposes of applying the provisions of the preceding paragraph, the profits attributed to the permanent establishment shall be determined each year by the same method, except if there is sufficient reason to do otherwise. 7. If the profit is included in the other articles of this Convention see income separately, this article shall not affect the other provisions of this article. Article 8 shipping and air TRANSPORT 1. profit from sea or air transport use in international traffic will be taxed only in the country where the actual place of management. 2. If a shipping company the actual place of management is located, then the ship will be considered that it is in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator is resident. 3. the provisions of part 1 shall also apply to profits from the participation in a pool, joint business or agency for international traffic, but they will be applied only to the part of the total profit commensurate with the interests of the members of the total business. 4. the application of this article, profits from the sea or air transport use in international traffic shall also include: (a)) return from sea and air vehicles-hire, hiring them without crew and supply; b) profit from containers (including trailers and related equipment for the transport of containers) use, maintenance or rental of goods or products; If such lease or such use, maintenance or rental is gained extra profit for which the applicable provisions of part 1. Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participate in the company of the other Contracting State, in the controls or owns part of the company's capital; or (b)) the same persons directly or indirectly participating in the enterprise of a Contracting State in the other Contracting State and enterprise management, controls or owns part of the company's capital, and in any of these cases, these two companies in commercial or financial relations are created or established by rules different from those provisions that the force between two independent enterprises, then any profits What would one of the companies, but the above provisions do not affect the Oscars can be included in the profits of this company, and it may be appropriate to impose taxes. 2. where a Contracting State includes in the profits of an enterprise of that State and Accordingly, the taxable profit for it, for which 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 tax, which is imposed on the profits of the second State. In determining this adjustment, take into consideration other provisions of this Convention and, if necessary, the competent authorities of the Contracting States for consultations. 3. the provisions of part 2 do not apply where legal, administrative or other proceedings has taken a final decision, which States that the activities which result in a return referred to in section 1 of the corrections, one of the companies involved have been imposed penalties for fraud, gross negligence or deliberate non-compliance of obligation. 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, from the "jouissanc" shares (entitled to part of the property of the public in the event of liquidation) or "jouissanc" (right to participate in company profits, not on the obligations of response), from the mining company shares from the founders ' shares or other debt obligations not resulting from the right to participate in company profits, income from other corporate rights, as well as other income, which in accordance with the laws of the country where the resident is a company that performs the distribution of profits, subject to the same taxation treatment as income from shares. 4. parts 1 and 2 shall not apply if the 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 a duty of retained earnings retained earnings of the company, even if the dividends paid or retained earnings consists in whole or in part from the other country of profit or income. 6. Notwithstanding any other provisions of this Convention from the company that is a resident of a Contracting State and which has a permanent establishment in the other Contracting State the profits which are taxable under part 1 of article 7, can withhold tax in the other Contracting State in accordance with the tax laws, if the profit is transferred to the main company, while withholding tax may not exceed 6 per cent of the amount of profit of which is deducted in that other Contracting State, the tax imposed on businesses. 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, a interest arising in a Contracting State, the implementation of which owner is the Government of the other Contracting State, its local authorities, central bank or any financial institution wholly owned by that Government, for which the relevant time period is agreed by the competent authorities of the Contracting States to the agreement, the first in that country will be exempt from taxation. 4. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage and 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. 5. the provisions of part 1 and 2 will not be applied, if the true owner of the interest, which is a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located there, and if the claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base whether article 7 of part 1 of the third sentence of that business. In this case, depending on the circumstances, apply article 7 or 14. 6. If the payer of the interest is a resident of a Contracting State, it will be considered that interest occurs 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. 7. If, on the basis of 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, then the provisions of this article shall be applied only to the last-mentioned 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 10 per cent of the total amount of the royalties. 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 broadcasts or transmissions on satellite, cable, fibre optic cable or similar technology used in public broadcasting, magnetic tape, disk or laser disk (software) to any of the patent , trade mark, design or model, plan, secret formula or process, or for the production, commercial, agricultural, or scientific equipment, or for the right to use them, or for information concerning industrial, commercial, agricultural or scientific experience (know-how), as well as technical assistance. 4. parts 1 and 2 shall not be applied, if the true 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 the other Contracting 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 whether article 7 of part 1 of the third sentence of that business. 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 will be considered that the royalties arise 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 remuneration of the author, which relate 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, then the provisions of this article shall be applied only to the last-mentioned 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 or income which a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real property, may be subject to taxes in the other country. 2. Capital gains 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, the disposal of an international traffic used for sea or air transport, or disposes of the property, which belongs to the sea or air transport means will be taxable only in the Contracting State in which the place of actual management of the company. 4. Capital gains, by a resident of a Contracting State alienates a benefit the company or other entities shares or comparable interests, which mainly property directly or indirectly consists of immovable property situated in the other Contracting State may be taxed in that other State taxes. 5. Capital gains generated by the disposal of any property other than that referred to in the preceding subparagraph, the property will be taxable only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. Contracting State resident income, providing professional services or other independent activities, will be taxable only in that State except in the following circumstances, when such income may be subject to taxes in the other Contracting State: a) if that person your actions the performance is regularly available in the other permanent base in the Contracting State; in this case, the other Contracting State taxes may be imposed only to the part of income attributable to the permanent base; or (b) if the person staying) in the other Contracting State for a period or periods exceeding in the aggregate reaching or 183 days in any 12-month period that begins or ends in the tax year; in this case, the other Contracting State taxes may be imposed only for part of the income gained by the person's activities carried out in this country. 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 paid employment, be taxable only in that State unless the 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 transport, taxes may be imposed in the Contracting State where the actual place of management. Article 16 DIRECTORS ' fees directors ' fees and other similar payments received by a resident of a Contracting State as the Board of Directors, supervisory board or other similar bodies, 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 on their individual activities in the other Contracting State may be taxed in that other State taxes. 2. If izpildītājmāksliniek or athlete's income on his individual activity in the area in question is paid rather than izpildītājmāksliniek or athlete himself but to another person, to the following income regardless of the 7, 14 and 15 the provisions of article 1 may be subject to taxes in the Contracting State in which the activity or sports izpildītājmāksliniek. 3. parts 1 and 2 shall not apply to income that izpildītājmāksliniek or athlete has learned about the State of the individual actions carried out when this state visit is wholly or mainly supported on one or both of the Contracting States or municipalities. In this case, the income tax imposed on only the Contracting State whose resident has this izpildītājmāksliniek or athlete. Article 18 pensions, life time, annual fees and social security payments 1. in accordance with article 19, part 2, rules for the pension, the person receiving the lifetime annuities and other similar remuneration received by a resident of a Contracting State for previous paid employment, be taxable only in that State. 2. Notwithstanding the provisions of part 1 of the pensions and other similar remuneration, which is paid in accordance with the Contracting State social insurance laws and regulations, will be taxable only in that State. 3. Paid pensions and life annuities, receivable and other periodic or irregular payments paid to the Government of a Contracting State or a political or administrative unit of local government for personal accident insurance will be 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 that State or entity or Government services will be taxable only in that State. (b) However, such salaries), fees and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that 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 who is paid from the funds set up for services provided by that person or entity for that State or municipality will be taxable only in that State. (b) However, such pension) will be taxable 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, and other similar remuneration for retirement, which is paid for services rendered in connection with a Contracting State or a political or administrative unit of local business. Article 20 students payments 1 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, this country will not be taxed if such payments are from sources that are not in the country. 2. For payments that are not addressed in part 1 of this article, and with regard to remuneration for independent personal services rendered study or internship period, the student, apprentice or trainee is entitled to the same tax exemptions, incentives or reductions, which are available to residents of the Contracting State which he is visiting for the purpose of study or internship. Article 21 teachers and researchers 1. Income, that of the teaching or research work shall receive physical person entering Contracting State with a view to teach or engage in research at a University, college or other recognized that Contracting State educational or scientific institution and directly before the arrival of a Contracting State has or had in the other Contracting State, the first resident in that country will not be taxable period not exceeding two years from the date on which that person first came those purposes, if such remuneration is from a source that is not in this country. 2. part 1 of this article shall not apply to income from research if such research is undertaken not in the public interest but primarily a private person or persons of interest. 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 will be taxable only in that State. 2. the provisions of part 1 does not apply to income, other than income from article 6 defined in part 2 of the real property, if the income beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation of the existing there, or give independent personal services in the other State through a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply the Convention in article 7 or 14. 3. Notwithstanding the provisions of part 1, if a resident of a Contracting State in the other Contracting State Lottery revenue-generating, crossword puzzles, races including horse racing, card games and other gaming or gambling or various types of betting winnings, such income may be taxed in the other Contracting State taxes. Article 23 avoidance of double taxation 1. In Latvia, double taxation shall be avoided as follows: (a) Where a resident of Latvia) derives income which, in accordance with this Convention may impose taxes in Morocco, then, unless national legislation is more favourable provisions, reduce the resident's permit Latvia income tax for an amount equal to the income tax paid in Morocco. These reductions must not, however, exceed that part of the income tax, which is calculated in Latvia before and where the application of this reduction is attributable to the income which may be taxed taxes in Morocco. (b)) (a) (a) for the application of this paragraph, if the company) – resident of Latvia receives a dividend from a company, resident in Morocco, in which it owns at least 10 percent of shares with full voting rights, the tax paid in Morocco will contain 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. Morocco double taxation will be avoided as follows: Where a resident of Morocco derives income which, in accordance with the provisions of this Convention may impose taxes in Latvia, then, reduce the resident's permit Morocco income tax for an amount equal to the income tax paid in Latvia. However, these reductions must not exceed the income tax part, what is calculated in Morocco before this fall and which is attributable to the income which may be taxed taxes in Latvia. 3. If a Contracting State in accordance with the laws adopted to promote economic development in this State, is assigned to the tax to which this Convention applies the exemption or reduction, the tax that would have been payable if such exemption or reduction is granted, are to be treated as having been paid for the parts 1 and 2. However, this provision is only applicable during the first five years of application of this Convention. 4. where in accordance with any of the provisions of this Convention to a resident of a Contracting State earned income is exempt from tax in that State, then the calculation of the tax on the income of a resident of the other, that State may take into account the exempted income. 24. Article 1 of the prevention of DISCRIMINATION on the nationals of a Contracting State in the other Contracting State shall not be 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 shall not be 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 7 or article 12 part 6 rules, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident, 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 shall not be interpreted so that they limit the right of a Contracting State to apply its domestic laws and regulations with regard to insufficient capitalization and internally, in so far as this legislation is not in contradiction with the General principles of the Convention. 7. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind. 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 in national 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 competent authority of the country where 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, national laws and the time limits laid down. 3. the national competent authorities should seek mutual agreement resolve any difficulties or eliminate doubts which may arise out of the interpretation or application of this Convention. They may also consult to avoid double taxation in cases not provided for in the Convention. 4. in order to reach agreement on these issues in the preceding subparagraph, the competent authorities of the Contracting States may communicate directly with one another, as well as the use of competent authorities or their representatives through 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 assistance in tax collection 1. The Contracting States agree that, to the extent permitted by their respective laws and regulations, to provide each other with the help of tax referred to in this Convention as well as with those tax related interest, expenses, and fines levied when these amounts are definitely determined in accordance with the requesting country's laws and regulations. 2. If a Contracting State requires you to provide assistance in tax collection and this requirement has agreed to the other Contracting State, that other State will charge these taxes under this second state tax revenues to the applicable laws, regulations, and taxes should be levied as the second State taxes. 3. Any claim of a Contracting State to provide assistance in the collection of the tax document, in accordance with the laws of this State affirm that the taxpayer's tax debt is fixed. 4. the requirement to collect the appropriate taxes will be considered privileged claims in the country where the request is received. 5. the provisions of this article may not explain that they impose on 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 take measures which would be inconsistent with the public interest (ordre public); (c)) to provide assistance, if the other Contracting Party has not taken all the necessary recovery or conservation measures, depending on the circumstances, which are available under its laws or administrative practice; (d)) to provide assistance in such cases when the administrative burden this State is clearly disproportionate to the other Contracting State the potential benefits. Article 28 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 29 entry into force 1. Contracting Governments shall notify each other of their compliance with their constitutional requirements for the entry into force of this Convention. 2. this Convention shall enter into force by 1. referred to in the last statement date and the rules in both Contracting States shall apply: (a)) in respect of taxes withheld at the time the costs – the amounts paid or credited to the account on the first day of January or after the calendar year following the year in which the this Convention enters into force; (b)) in the case of other income taxes – tax due on any taxation year or period that begins on the first day of January in the calendar year or after the following the year in which this Convention enters into force. Article 30 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 following the five-year period after the entry into force of the Convention. In this case the Convention in both Contracting States will end: a) in respect of taxes withheld at the time the costs – the amounts paid or credited in the calendar year of January or after the first day of the calendar year following the year in which the notice has been filed for dissolution; (b)) in the case of other income taxes – tax paid in any taxation year or period beginning 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 whereof, the respective Governments of their duly authorised, have signed this Convention. The Convention is drawn up in two copies in the 24 July 2008 in Latvian, Arabic, French and English, in addition, all texts being equally authentic. Different case is decisive for the interpretation of the text in English.  

On behalf of the Republic of Latvia, on behalf of the Kingdom of Morocco of the Penk Norman Latif Akharbach, Ministry of Foreign Affairs State Secretary for Foreign Affairs and cooperation State Secretary ministij CONVENTION BETWEEN the REPUBLIC OF Latvia AND the KINGDOM OF Morocco 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 Kingdom of Morocco (Menu Rngton Line4) promote and strengthen it, their economic relations by concluding a Convention 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 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"); (b)) in Morocco: (i) the income tax; and (ii) the corporation tax; (hereinafter referred to as "Moroccan 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. Article 3 GENERAL DEFINITION 1. For the purpose of this Convention, unless the context otherwise requires: a the term "a) Contracting State" and "the other Contracting State" mean Latvia or Morocco, as the context requires; (b)) the term "United States" means the Republic of Latvia and, when used in the sense of location, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the law of Latvia and in accordanc with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub soil and their-natural resources; (c)) the term "MC" means the Kingdom of Morocco and, when used in a sense, the location term "MC" includes: (i) the territory of the Kingdom of Morocco, the territorial sea thereof; and (ii) the maritime areas beyond the territorial sea, including the seabed and subsoil thereof the (continental shelf) and the exclusive economic zone over which Morocco exercises sovereign rights, in accordanc with its domestic law and international law, for the purpose of exploration and exploitation of the natural resources of such areas; (d) the term "tax") means Latvian tax or tax, Moroccans as the context requires; e the term "person") includes an individual, a company and any other body of persons, including a partnership; (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 that has its place of effective management in a Contracting State as defined under the paragraph 3 of article 4, except when the ship or aircraft is operated solely between places in the other Contracting State; I) the term "competent authority" means: (i) in Latvia, the Ministry of finance or its authorised representative; (ii) in Morocco, the Minister of finance or his 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 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 an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests); (b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated. For the purpose of this Convention the place of effective management, shall be deemed to be situated in the Contracting State in which the head office and legal address of the person are situated. Article 5 permanent establishment 1. For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a a place of management); (b)) a branch; c) an Office; (d) a factory;) e) a workshop; (f) a mine, an oil) or gas well, a quarry or any other place of exploration and extraction of natural resources; g) a sales outlet; and (h)) a warehouse to put at the disposal of a person providing storage facilities for others. 3. The term "permanent establishment" also encompass: (a) a building site, a) a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities lasts more than six months; (b)) the furnishings of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than three months within any twelve month period; c) activities carried on in a Contracting State in connection with the exploration or exploitation of the sea bed and its sub soil and their-natural resources situated in that State, if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period; d) an enterprise, which provides in a Contracting State services, facilities or plant and machinery on hire used for the prospecting for, or extraction or exploitation of mineral, the oil in that State for a period or periods aggregating more than 30 days in any twelve month period. 4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other. Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of general law respecting landed property apply, any option or similar right in respect of their immovabl property, the usufruc 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, boats and aircraft shall not be regarded as immovabl property. 3. The provision of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovabl property. 4. Where the ownership of shares or other rights (including corporate rights) in a company or any other entity created under the law of a Contracting State of the owner of such entitl shares or other rights to the enjoymen of immovabl property held by that company or other entity, that income from the use, letting, or use in any other form of such right may be taxed to the enjoymen in the Contracting State in which the immovabl property is situated. 5. The provision of paragraphs 1, 3 and 4 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. However, profits derived from the sale of goods or merchandise of the same or similar kind as those sold, or from other business activities of the same or similar kind as those effected, through that permanent establishment may be considered attributabl to that permanent establishment if it is established that such sales or activities were structured in a manner intended to avoid taxation in the State where the permanent establishment is situated. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In the determination of the profits of a permanent establishment, there shall be allowed as a deduction in "of which the expense incurred for the purpose of the permanent establishment, including Executive and general administrative expense so incurred, whethers of in the State in which the permanent establishment is situated or elsewher. However, no such deduction in "shall be allowed in respect of non, if any, paid (otherwise than towards reimbursemen of actual expense) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of the royalt, fe, or other similar pay subscriptions in return for the use of patents or other rights, or by way of commission , for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on money lent to the permanent establishment. Likewis, from the account shall be taken, in the determination of the profits of a permanent establishment, for non, charged (otherwise than towards reimbursemen of actual expense) by the permanent establishment to the head office of the enterprise or any of its other offices. 4. Insofar as it has been customary in a Contracting State to determin the profits to be attributed to a permanent establishment on the basis of an apportionmen of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclud that Contracting State from determining the profits to be taxed by such an apportionmen as may be customary; the method of apportionmen, however, the adopted shall be such that the result shall be in accordanc with the principles led in this article. 5. From the profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which the deal with separately in other articles of this Convention, then the provision of those articles shall not be affected by the provision of this article. Article 8 SHIPPING AND AIR transport 1. Profits from the operations of ships or aircraft in international traffic shall be taxabl only in the Contracting State in which the place of effective management of the enterprise is situated. 2. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident. 3. The provision of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency but only to so much of the profits so derived as is attributabl to the participant in proportion to its share in the joint operations. 4. For the purpose of this article, profits from the operation of ships or aircraft in international traffic shall also include: a profits from the rental) on a barebo basis of a ship or aircraft; b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is it the profits they incidentals which the provision of paragraph 1 apply. 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. 3. The provision of paragraph 2 shall not apply where juridical, administrative or other legal proceedings have resulted in a final ruling that by actions giving rise to an adjustment of profits under paragraph 1, one of the enterprises concerned is liabl with respect to the penalty of the fraud, gross or wilful default gligenc not. Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not: (a) exceeds 100 per cent) (6) 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, "jouissanc", "jouissanc" shares or rights, mining shares, founder ' shares or other rights, not being debt-claims, participating in profits, income from other corporate rights, as well as other income which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State or of deriv profits income from the other Contracting State, that other State may not impost any tax on the dividends paid by the company, except insofar as such dividends to be paid to a resident of that other State or insofar as the holding in respect of which the dividend is paid is effectively connected with a permanent establishment or a fixed base situated in the a to get other State , nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State. 6. Notwithstanding any other provision of this Convention, where a company which is a resident of a Contracting State has a permanent establishment in the other Contracting State, the profits of the taxabl under paragraph 1 of article 7 may be subject to a withholding tax in that other State, in accordanc with its taxation laws, when the profits are remitted to the head office , but the withholding tax so charged shall not six (6) exceeds 100 per cent of the amount of those profits, after deducting therefrom the corporation tax imposed thereon in that 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 ten (10) per cent of the gross amount of the interest. 3. Notwithstanding the provision of paragraph 2, interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including local authorities, though the Central Bank or any financial institution wholly owned by that Government as may be agreed from time to time between the competent authorities of the Contracting States shall be the main from tax in the first-mentioned State. 4. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage and 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. 5. The provision of paragraphs 1 and 2 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 , or business activities referred to in the third line of paragraph 1 of article 7. In such cases, the provision of article 7 or article 14, as the case may be, shall apply. 6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this Convention. Article 12 to 1 to ROYALT Royalt arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may be taxed in royalt also in the Contracting State in which they «arise and according to the law of that State, but if the beneficial owner of the royalt to is a resident of the other Contracting State, the tax so charged shall not exceeds 100 ten (10) per cent of the gross amount of the 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 or films or tapes for radio or television broadcasting or broadcasting by satellite, cable, optical fibre or similar technology used for public broadcasting , magnetic tapes, discs or laser disc (soft ware), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, agricultural or scientific equipment, or for information concerning industrial, commercial, agricultural or scientific experience (know-how), as well as technical assistance. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other Contracting 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 with or fixed base, or business activities referred to in the third line of paragraph 1 of article 7. In such cases, 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 or income derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains 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 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 taxabl only in the Contracting State in which the place of effective management of the enterprise is situated. 4. Gains derived by a resident of a Contracting State from the alienation of shares or the interests of a company comparabl or other entity, the property of which consist directly or indirectly principally of immovabl property situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this article, shall be taxabl only in the Contracting State of which the alienator is a resident. Article 14 independent PERSONAL services income derived by a 1 resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxabl only in that State except in the following circumstanc, when such income may also be taxed 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; in that case, only so much of the income as is attributabl to that fixed base may be taxed in the other Contracting State; or b if his stay) in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in-the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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, 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, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated. 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, supervisory board or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. Article 17 artistes AND SPORTSPERSON 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 sportsperson, 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 sportsperson in his capacity as such notes to the accru entertainer or sportsperson 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 sportsperson are exercised. 3. The provision of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsperson if the visit to that State is wholly or mainly supported by public funds of one or both of the Contracting States or local authorities thereof. In such case, the income shall be taxabl you only in the Contracting State of which the entertainer or sportsperson is a resident. Article 18 PENSION, life AND SOCIAL SECURITY payments ANNUIT 1. Subject to the provision of paragraph 2 of article 19, pension, life and other similar remuneration annuit paid to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. 2. Notwithstanding the provision of paragraph 1 of this article, and others in similar pension remuneration paid under the social security legislation of a Contracting State shall be only in the taxabl you state. 3. Pension and life, and others paid to annuit periodical or occasional payments made by the Government of a Contracting State, a political subdivision or a local authority thereof or a in respect of insuring their personnel accidents, 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 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 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 other 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. Article 20 STUDENTS payments which a 1 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. 2. In respect of payments not covered by paragraph 1 of this article, and remuneration for personal services rendered dependent during such education or training, a student, an apprentice or a trainee shall be entitled to the same relief, exemption or reduction in respect of taxes on income as are available to the residents of the Contracting State he is visiting. Article 21 teachers AND RESEARCHER. An individual who visits a Contracting State generally for the purpose of teaching or carrying out research at a university, college or other recognised educational or scientific institution in 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, provided that such remuneration is derived from sources outside that State. 2. The provision of paragraph 1 of this article shall not apply to income from research if such research is undertaken not in the 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 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 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. 3. Notwithstanding the provision of paragraph 1, if a resident of a Contracting State from sources of income deriv within the other Contracting State in the form of winning from lotter, crossword puzzles, races including horse races, card games and other games of any sort or gambling or betting of any nature whatsoever, such income may be taxed in the other Contracting State. Article 23 ELIMINATION OF double TAXATION 1. In Latvia shall be avoided double taxation as follows: (a)) where a resident of Latvia's income which, deriv in accordanc with this Convention, may be taxed in Morocco, 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 Morocco. 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 Morocco. (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 Morocco in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Morocco 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 Morocco double taxation shall be avoided as follows: where a resident of Morocco's income which, deriv in accordanc with the provision of this Convention, may be taxed in the United Kingdom, Morocco shall allow as a deduction in "from the tax on the income of that resident an amount equal to the income tax paid in Latvia. However, such shall not exceeds 100 Marbles that part of the income tax, as computed before the deduction in "is given, which is attributabl to the income which may be taxed in the United Kingdom. 3. Where, in accordanc with the law of a Contracting State, an exemption from, or a reduction of, taxes covered by this Convention is granted for the purpose of encouraging economic development in that Contracting State, the tax which would have been paid but for such exemption or reduction shall be deemed to have been paid for the purpose of paragraphs 1 and 2 of this article. This provision, however, is applicable only for the first five years during which this Convention is effective. 4. Where, in accordanc with any provision of this Convention, income derived by a resident of a Contracting State is a tax in the main from a State, such State may not vertheles, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. Article 24 NON-DISCRIMINATION 1-nationals of a Contracting. State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more 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 7 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 not be construed as preventing either Contracting State from applying the provision of its domestic law as regards the thin capitalisation and transfer pricing, insofar as this legislation is not contrary to the general principles of this Convention. 7. 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 this 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 difficult to doubt arising as it is or the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 4. The competent authorities of the Contracting States the may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. Article 26 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is 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 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 assistance IN COLLECTION 1. The Contracting States agree, to the exten the permitted by the legislation and regulations their respectiv, to lend assistance to each other in order to collect the taxes covered by this Convention as well as interests, costs and penalties of delay pertaining to these taxes when such non-its determined by under the legislation and regulations of the requesting State. 2. In the case of a request by a Contracting State for the collection of taxes which has been accepted for collection by the other Contracting State, such taxes shall be collected by that other State in accordanc with the laws applicable to the collection of its own taxes and as if the taxes to be collected were its own SOS taxes. 3. Any request for collection by a Contracting State shall be accompanied by such certificate as is required by the law of that State to establish that the tax by the taxpayer of the Owings have been finally determined. 4. The claim of òàæó to the tax to be collected shall not be deemed as a privileged claim in the requested State. 5. In no case shall the provision of 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 carry out the ") which would be contrary to public policy (ordre public); (c) to provide assistance if) the other Contracting State has not pursued all reasonable measure of collection or conservancy, as the case may be, available under its laws or administrative practice; (d)) to provide assistance in those cases where the administrative burden for that State is clearly disproportionat to the benefit to be derived by the other Contracting State. Article 28 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 29 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 date of the later of the notifications referred to in paragraph 1 and its provision shall have effect in both Contracting States: a in a) in respect of taxes withheld at source, on a non-paid or credited on or after the first day of January in the calendar year next following the year in which the Convention enter into force; (b)) in respect of other taxes on income, for taxes chargeabl for any fiscal year or period beginning on or after the first day of January in the calendar year next following the year in which the Convention enter into force. Article 30 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 after the fifth year following the year in which the Convention has entered into force. In such event, the Convention shall cease to the have effect in both Contracting States: a in respect of taxes) withheld at source, on a non-paid or credited on or after the first day of January in the calendar year next following the year in which the notice has been given; (b)) in respect of other taxes on income, for taxes chargeabl for any fiscal year or period beginning on or after the first day of January in the calendar year next following the year in which the notice has been given. In witness whereof, the undersigned, duly authorised by the by the Governments of their respectiv theret, have signed this Convention. Done in duplicate at Riga this 24 day of July 2008, in the Latvian, Arabic, French and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Republic of Latvia Mr. Norman Penk state secretary Ministry of Foreign Affairs For the Kingdom of Morocco Mr. the state secretary Latif Akharbach Ministry of Foreign Affairs and Co-operation