The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Government of the Kyrgyz Republic of agreements for avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes article 1. 7.2006 December Bishkek signed by the Government of the Republic of Latvia and the Government of the Kyrgyz Republic an agreement on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Treaty) this law is adopted and approved. 2. article. The agreement shall enter into force for the period specified in article 27 and in order, and the Ministry of Foreign Affairs shall notify the newspaper "journal". 3. article. The law shall enter into force on the day following its promulgation. To put the contract in law Latvian and English. The Parliament adopted the law of 24 May 2007. The President of the Parliament instead of the President i. Emsis, Riga, 12 June 2007 by the Government of the Republic of Latvia and the Government of the Kyrgyz Republic an agreement on 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 Kyrgyz Republic, people's willingness to conclude an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, to develop and strengthen cooperation in economic, science , technical and cultural cooperation, agree on the following: article 1 persons covered this AGREEMENT shall apply to persons Contract, one or both of the Contracting States residents. Article 2 taxes covered by the AGREEMENT. This agreement applies to income taxes, which are imposed on the Contracting State or of its administrative territorial units or local authorities, irrespective of the good this kind of 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 agreement applies, in particular: (a)): (i) in Kyrgyz legal person of profit and other income tax; and (ii) the individual income tax; (hereinafter-the Kyrgyz taxes); (b)): (i) corporate income tax; (ii) the individual income tax; (hereinafter-the Latvian tax). 4. This agreement shall also apply to any identical or substantially similar taxes which, supplementing or replacing the existing taxes, introduced after the signing of this agreement. Both 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 Treaty: a) the terms "Contracting State" and "the other Contracting State" mean, depending on context or Kyrgyzstan Latvia; (b)), the term "Kyrgyzstan" means the Republic of Kyrgyzstan. The term "Kyrgyzstan", used in a geographical sense, represents the area where the Kyrgyz Republic in accordance with international law, exercises sovereign rights and jurisdiction, and which are in force tax legislation of the Kyrgyz Republic; (c)), 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 are implemented in Latvia of rights on land and sea depths and natural resources contained therein; (d)) the term "person" means a natural person, company, or any other Association of persons; e the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association; (f) the terms ") of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise company, run by a resident of a Contracting State, and the company that runs a resident of the other Contracting State; (g)) the term "international traffic" means any carriage by sea, air or road transport vehicles, by contracting a public company except where sea, air or road vehicles move only in the other Contracting State; h) the term "competent authority" means: (i) Kyrgyzstan-the Ministry of finance or its authorised representative; (ii) in Latvia – the Ministry of finance or its authorised representative; I) the term "national" means: (i) any natural person who has the nationality of a Contracting State; (ii) any legal person, partnership or association whose status stems from the existing Contracting State legislation. 2. a Contracting State at any time during the application of this agreement, all terms not defined therein, have the meanings in which they State Contracting laws at that time are used due to the taxes covered by the agreement, unless the context otherwise, besides not risk‐adjusted this country's relevant tax legislation meaning prevails over other laws of this state the intended meaning. Article 4 resident 1. In this agreement, 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, or any other similar criteria, and also includes the State and any of its territorial or local administrative units. However, this term does not include those individuals in that State taxes are imposed only in respect of 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) that person only) for residents of the country in which they are habitually resident; If you are habitually resident in two countries, this person is considered a resident of the country only, with which it has closer personal and economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it is not a permanent residence in one of the two countries, this person is considered a resident of the country only, which is its usual home; (c) if the person's usual) home in both countries or is not one of them, it is considered to be the only resident in the country, of which this person; (d)) if that person is a national of both States or no citizen of this country, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, in accordance with the provisions of part 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to resolve the matter by mutual agreement, to determine the type of application of this agreement to such person. Article 5 permanent establishment 1. In this agreement, 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 extraction related site; and (g)) farm, pasture or forest, which is carried on farming, agriculture or forestry. 3. The term "permanent establishment" includes a building site, a construction, Assembly or Assembly project if these work or the project is going on for more than nine months. 4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall not include: (a) the use of buildings and equipment) only and exclusively the goods belonging to, or for the storage of the products demonstrated or delivery; (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 only and exclusively to conduct business any other preparatory or ancillary jobs; f) specific action site intended only and only 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 is empowered to enter into contracts state the company name, and it constantly uses this power, then in all activities carried out by such person for your business, it is considered that the company has a permanent establishment in the country concerned, unless such person has carried out only part 4 actions foreseen in the that perform certain actions in place, the place of action under the said part is not considered permanent representation. 6. it will be considered that the company does not have permanent representation in the Contracting State where the undertaking is established in that country, only through brokers, sales agent or any other agent of an independent status, provided that such persons perform their normal business activities. 7. the fact that a company which is a resident of a Contracting State controls the company that is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking in itself does not mean that any of these companies is the second permanent representation of society. Article 6 INCOME from real property 1. income which a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State taxes. 2. The term "immovable property" shall have the meaning which it has its laws and regulations of a Contracting State in which the property concerned is located. In any case, this term covers property which belongs to real estate property, livestock and equipment used in agriculture and forestry, rights to which the law of land ownership rules, real-estate usage rights 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. Maritime, air and road transport vehicles are not considered real estate. 3. the provisions of part 1 apply to the income from real estate direct use, letting or use in any other way, as well as income from the alienation of immovable property. 4. If the company's shares or other corporate rights give the holder the right to public use of the property, the income from the direct use, 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 4 shall apply in relation to income from the company's real estate, as well as income from real property used for independent individual services. Article 7 business profits 1. Contracting State company profits are taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent representation of the existing there. If the enterprise carries on business in that way, the company's profits may impose taxes in the other country, but only to the profit, which can be attributed to the permanent establishment. 2. in accordance with the provisions of part 3, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit amount as it would if it had been separated and independent company that performs the same or similar business activities under the same or similar conditions and independently carry out transactions with the company that it is a permanent establishment. 3. in determining the profits of a permanent representation in that Contracting State, are allowed to deduct the expenses incurred for the purposes of the standing representative offices located in the country or elsewhere, including operational and general administrative costs. However, the following deductions are not allowed for payments (other than the actual expenditure), the cost of the independent representation of the company or any other part thereof 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 amount of money that is lent to an independent agency. 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. the Permanent Mission shall not apply only to profits 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 agreement are considered separate income type, this article shall not affect the other provisions of this article. Article 8 international traffic 1. Contracting State company profits gained from the sea, air or road vehicles in international traffic, the use of taxable only in that State. 2. the provisions of part 1 shall also apply to profits from the participation in a pool, joint business or international traffic transport agency. Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participating in the other Contracting State, the company's management or control or it owns part of the company's capital; or (b)) the same persons directly or indirectly participating in the enterprise of a Contracting State in the other Contracting State and the company's management or control or they own part of the company's capital, and in any of these cases, these two companies in commercial or financial relations 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 taxes accordingly profits on it, in respect of which no other country in the other Contracting State, the company has been taxed, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, the other country take appropriate adjustment for the size of the tax What are the gains of the other country. In determining this adjustment, take into consideration other provisions of this agreement and, if necessary, the competent authorities of the Contracting States for consultations. Article 10 dividends 1. Dividends by the 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 dividend) total 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 the profits of this company, as well as income from other rights which, in accordance with its national laws and regulations 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, for which dividends are 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 dividends paid to a resident of the other State, or if the participation, for which dividends are actually related to the permanent representation or permanent base in another country; Neither also 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. 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. If the interest holder is a real bank or any other financial institution, and interest charges due to the bank or other financial institution on loans, then the tax must not exceed 5 percent of the total amount of interest. 3. Notwithstanding the provisions of part 2, interest arising in a Contracting State, the implementation of which owner is the other Contracting Government, including its territorial administrative units and local governments, the central bank or any financial institution wholly owned by that Government, or interest payments on the loans, which guarantee given this Government the first in the 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 be considered dividends. Interest received on payments made during, not be regarded as interest for the application of the provisions of this article. 5.1, 2, and 3. the subparagraph does not apply if the interest owner will exercise that 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 pay interest, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. 6. If the payer of the interest is a resident of a Contracting State, it shall be deemed that the interest generated in this country. If, however, the person paying the interest, whether that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which incurred debt obligations for which pay interest and if such interest is paid (bear) permanent establishment or fixed base, then consider 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 the 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 apply 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 agreement. 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 5 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 motion picture on any patent, trademark, design or model, plan, secret formula or process, or for the production, commercial, or scientific equipment, or for the right to use them, or for information concerning production , commercial or scientific experience. 4. parts 1 and 2 shall not apply 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 that other State through a permanent base located there, and if the right or property, paid for by the royalties is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the payer of the royalties is a resident of a Contracting State, it shall be deemed 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, which is the result of an obligation to pay the royalties, and if the payment of the royalties (bear) that permanent establishment or fixed base, then considers the royalties arise in the State in which the permanent establishment or fixed base. 6. If, on the basis of the special relationship between the payer of royalties and royalties shall implement the owner or between both of them and some other person, the amount of the royalties relating to the use, right or information for which it is paid, exceeds the amount of royalties that would have been able to implement a single payer and the owner if they would not have this special relationship, then the provisions of this article shall apply only to the last-mentioned amount. In that case, the excess part of the payments in this amount are taxed according to each Contracting State laws and regulations, taking into consideration other provisions of this agreement. Article 13 capital gains 1. Capital gains, by a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real estate or shares of one company, which mainly consists of the following assets of the real property may be taxed in that other State taxes. 2. Capital gains that accrued, disposing of property, which is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State, or disposing of property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which created the independent personal services, including capital gains from such permanent missions (alone or with the whole enterprise) or of such a permanent disposal base disposal can impose taxes in the other Contracting State. 3. Capital gains by the public company, which uses the sea, air or road vehicles in international traffic, shall forfeit the use in international traffic, maritime, air or road vehicles or disposes of the property, which belongs to the sea, air or road vehicles, is taxed only in the country. 4. Capital gains generated by the disposal of any property that is not 1, 2, and 3. the property referred to, are taxable only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. resident of a Contracting State – physical person's income from a professional or other independent activities are taxable only in that State. This income may be subject to tax in the other Contracting State if: (a) the natural person) your operational needs using it regularly available permanent base in the other Contracting State but only to the extent that the income is attributable to this permanent base; or (b)) this natural person resident in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any twelve month period commencing or ending in the taxation year, but only part of the income gained by the person in the other Contracting State of the transactions. 2. The term "professional activity" 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 and article 19 of the regulations for the payment of salaries and other similar remuneration, which A resident of a Contracting State receives for gainful employment are taxable only in that State unless paid work is not performed in the other Contracting State. If the salaried work is performed in the other Contracting State, the remuneration received for it can impose taxes in the other country. 2. Notwithstanding the provisions of part 1 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 use in international traffic, maritime, air or road vehicles, can impose taxes of the Contracting State of which the company is resident who uses the following maritime, air or road vehicle. Article 16 DIRECTORS ' fees directors ' fees and other similar payments received by a resident of a Contracting State as the Board of directors or other similar institutions in society, which is a member of the other Contracting State, a resident may be taxed in that other State taxes. Article 17 artists and athletes 1. articles 14 and 15 of the regulations to the income of a resident of a Contracting State as izpildītājmāksliniek, such as a theatre, film, radio or television artist, 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 field in question, rather than pay the same izpildītājmāksliniek or athlete 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 from a Contracting State made individual actions when visiting this country wholly or largely supported one or both of the Contracting States or the territorial administrative unit or municipality funds, or if such a visit takes Contracting Governments concluded agreements on cooperation in the field of culture. In this case, the income taxable only in the Contracting State of which the resident is this izpildītājmāksliniek or athlete. Article 18 pensions in accordance with article 19 of part 2 of the regulations for pensions and other similar remuneration received by a resident of a Contracting State for previous paid employment are taxable only in that State. Article 19 government service 1 a) for salaries, fees and other similar remuneration, other than a pension, and a natural person the cost of Contracting State or its territorial administrative unit or municipality of this State, entity or municipality services are taxable only in that State. (b) However, such salaries), fees and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that 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 its territorial administrative unit or municipality, or the cost of the funds set up for services provided by that person or entity for this country or municipality, is taxed only in the country. (b) However, such pension shall be) taxable only in the other Contracting State if the individual is a resident of that other State and the citizen. 3.15, 16, 17, and article 18 shall apply to salaries, wages, other remuneration and pensions similar to that paid for services provided in respect of the Contracting State or the territorial administrative unit or municipality's business. Article 20 students payments which a residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State and who was the first resident in that country have come only for the purpose of study or internship, in this country are not taxed if such payments are from sources that are not in the country. Article 21 other income 1. Other previous articles of this contract not specified in the resident of a Contracting State shall, whatever their income sources are taxable only in that State. 2. the provisions of part 1 does not apply to income, other than income from article 6 defined in part 2 of the real property, if the income beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation of the existing there, or give independent personal services in the other State through a permanent base located there, and if the rights or property of which receives this income is actually related to the permanent representations, or permanent base. In this case, depending on the conditions of this contract apply 7. the provisions of article 14. 3. Apart from 1 and 2, part income as gambling or lottery winnings gained in the other Contracting State may be taxed in that other Contracting duties in the country. Article 22 double tax methods 1. Kyrgyzstan double taxation is resolved by the following: (a) if the Kyrgyz resident) derives income which, in accordance with this agreement may be subject to taxes in Latvia, then a resident of Kyrgyzstan permit to reduce the income tax on the amount equal to the income tax paid in Latvia. The above reduction may not be greater than the amount that meets Kyrgyzstan estimated tax on this income. (b) if the Kyrgyz resident) derives income which, in accordance with the terms of this agreement may be subject to taxes in Latvia, only then may include this income in Kyrgyzstan total taxable income only in order to determine the income tax rate applicable to the taxation of Kyrgyzstan. 2. in the case of Latvia, double taxation is avoided by the following: (a) where a resident of Latvia) derives income which, in accordance with this agreement may be subject to taxes in Kyrgyz, then unless the Latvian domestic laws do not provide for more favourable provisions, reduce the resident's permit Latvia income tax for an amount equal to the income tax paid in Kyrgyz. Such reduction may 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 Kyrgyzstan. (b)) (a) (a) for the application of this paragraph, if society)-a resident of Latvia receives a dividend from a company-Kyrgyz residents, in which it owns at least 10 percent of shares with full voting rights, the tax paid in Kyrgyzstan include not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the profits of the company out of which the dividend was paid. 23. Article 1 of the prevention of DISCRIMINATION on the nationals of a Contracting State in the other Contracting State shall not apply to any taxation or any requirements associated with it, which is 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 other citizens of this country. This provision shall, notwithstanding the provisions of article 1, also apply to persons who do not have one or both of the Contracting States residents. 2. stateless persons – residents of a Contracting State in one of the Contracting States not subject to taxation or related requirements that are different or more burdensome than the taxation or the related requirements which, in the same circumstances, in particular with respect to residence, applies or may apply to citizens 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 obligations. 4. Except where the applicable part 1 of article 9, article 11 part 7 or 6 of article 12, the provisions of part, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident by establishing this company taxable profit, the report follows the same rules as if it would cost the first resident of that State. 5. the Contracting State whose capital, in whole or in part, directly or indirectly, belongs to one or more residents of the other Contracting State or in full or in part, directly or indirectly control these residents, the first State may not be subject to any taxation or any requirements associated with it, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or which is more burdensome for them. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind and name. Article 24 mutual conciliation procedure 1. If a person believes that one or both of the Contracting States concerning this person causes or will cause the taxation which does not comply with the terms of this agreement, that person may, irrespective of the country's domestic legislation that remedies to submit complaints to the competent authority of the country of which the person is resident, or if the complaint refers to part 1 of article 23, the national competent authority of which are this person. The complaint shall be submitted for review within three years of the first notification of the action which led to the terms of this agreement without corresponding 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 Contracting State, the competent authority, to prevent the contract inappropriate taxation. Any such agreement is reached is due irrespective of the Contracting State of the domestic laws and the established time limits. 3. The competent authorities of the Contracting States shall endeavour by mutual agreement to solve any problems or prevent the doubts that may arise out of the interpretation or application of this agreement. They may also consult to avoid double taxation in this contract in the event of unforeseen circumstances. 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 25 exchange of information 1. The competent authorities of the Contracting States shall exchange the information necessary for the provision of this agreement or of the domestic laws and enforcement for all the type and name of the taxes imposed on Contracting States or their territorial or local administrative units, in so far as these regulations not inconsistent with this agreement. 1 and 2 of the Treaty, article does not limit the exchange of information. Any information received by a Contracting State shall be considered as sensitive as information produced in accordance with the laws of this State, and may be disclosed only to persons or authorities (including courts and administrative authorities) which are involved specified in the first sentence or collection of the tax calculation, the use of coercive measures or proceedings, or in appeals related to these taxes. Such persons or authorities use this information only for the purposes mentioned above. They may disclose the information in public hearings or in judgements. 2. the provisions of part 1 can 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 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 26 diplomatic missions and consular staff nothing in this Agreement shall affect the diplomatic missions or consular posts personnel fiscal privileges in accordance with the General principles of international law or the provisions of special agreements. Article 27 entry into force 1. Contracting Governments diplomatic channels shall inform each other of the necessary requirements for the entry into force of this Treaty. 2. this Convention shall enter into force with this article referred to in paragraph 1, the last statement date, and its provisions both of the Contracting States shall apply: (a)) in respect of taxes withheld at the time the cost-income accruing on the first day of January in the calendar year or after the following the year in which this agreement enters into force; (b)) in the case of other income taxes-taxes payable in any tax year that begins on the first day of January in the calendar year or after the following the year in which this agreement enters into force. Article 28 termination this Agreement shall remain in force as long as one Contracting State it shall be terminated. Each Contracting State may terminate this contract shall be submitted to a diplomatic path written notice of termination at least six months before any end of the calendar year. In this case, the Agreement shall cease to have effect in both Contracting States: a in respect of taxes) withheld at the time the cost-income accruing on the first day of January or after the calendar year following the year in which the notice is given; (b)) in the case of other income taxes-taxes to be paid in any taxation year that begins on the first day of January or after the calendar year following the year in which the notice is given. In witness thereof, the undersigned, being duly authorised, have signed this agreement. The contract drawn up in Bishkek two Exo 2006. by plāro on December 7, Kyrgyz, Russian, Latvian and English languages, each text being equally authentic. Different case is decisive for the interpretation of the text in English.

The Kyrgyz Republic of the Republic of Latvia, on behalf of the Government of the Government of the Žaparov Apokin Igor Akilbek agreement BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the KYRGYZ REPUBLIC 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 Kyrgyz Republic, an agreement the conclud (menu Rngton Line4) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and to develop and strengthen economic, scientific, technical and cultural cooperation, have agreed as follows: article 1 PERSONS COVERED this Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 taxes COVERED 1. This agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its administrative 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 agreement shall apply to: (a) in particular) in Kyrgyzstan: (i) the tax on profits of legal persons and others revenue; and (ii) the income tax on individual; (hereinafter referred to as "Kyrgyzstan tax"); (b)) in the United Kingdom: (i) the enterprise income tax (income tax of enterprises); (ii) the personal income tax (will tax revenue); (hereinafter referred to as "Latvian tax"). 4. The agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify the other of any each significant changes that have been made in their taxation laws of respectiv. Article 3 GENERAL DEFINITION 1. For the purpose of this agreement, unless the context otherwise requires: a the term "a) Contracting State" and "the other Contracting State" mean Latvia or Kyrgyzstan, as the context requires; (b) the term "Kyrgyzstan") means the Kyrgyz Republic. When used in the sense the location term "Kyrgyzstan" means the territory on which the Kyrgyz Republic carr out the sovereign rights and jurisdiction in accordanc with the international law and in which the taxation law of the Kyrgyz Republic with the in force; (c)) 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; (d) the term "person") includes an individual, a company and any other body of persons; e the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose; (f) the term ") enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; g) the term "international traffic" means any transport by a ship, aircraft or road vehicle operated by an enterprise of a Contracting State, except when the ship or aircraft or road vehicle is operated solely between places in the other Contracting State; h) the term "competent authority" means: (i) in Kyrgyzstan, the Ministry of finance or its authorised representative; (ii) in Latvia, the Ministry of finance or its authorised representative. (I) 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 agreement 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 agreement 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 agreement, 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 or any other criterion of a similar nature, and also includes that State and any subdivision or local authority thereof administrative. 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, the competent authorities of the Contracting States shall endeavour to the settle the question by their mutual agreement and determin the mode of application of the agreement to such person. Article 5 permanent establishment 1. For the purpose of this agreement, 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 extraction of natural resources, and (g)) (a) the farm, or forestry pastur where agricultural, pastoral or forestry activities are carried on. 3. A building site, a construction, assembly or installation project constitut a permanent establishment only if it lasts more than nine months. 4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 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, 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, aircraft and road vehicles 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 property, as well as immovabl to income from the alienation of property immovabl. 4. Where the ownership of shares or other corporate rights in a company the owner of entitl such shares or corporate rights to the enjoymen of immovabl property held by the company, the income from the direct 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. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In determining the profits of a permanent establishment in a Contracting State, 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 payments 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. 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 agreement, then the provision of those articles shall not be affected by the provision of this article. Article 8 INTERNATIONAL TRAFFIC 1. Profits derived by an enterprise of a Contracting State from the operation of ships, aircraft or road vehicles in international traffic shall be taxabl only in that State. 2. The provision of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Article 9 ASSOCIATED enterprises 1. Where (a) an enterprise of a Contracting) State of directly or indirectly participat in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons directly or indirectly the participat in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State , and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State-and taxes accordingly-profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises , then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provision of this agreement and the competent authorities of the Contracting States shall if the cessary not consult each other. Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not (a) 12:5 per cent) of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividend; b) 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall not be affec the taxation of the company in respect of the profits out of which the dividend is paid with. 3. The term "dividends" as used in this article means income from shares, "jouissanc", "jouissanc" shares or rights, mining shares, founder ' shares or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State or of deriv profits income from the other Contracting State, that other State may not impost any tax on the dividends paid by the company, except insofar as such dividends to be paid to a resident of that other State or insofar as the holding in respect of which the dividend is paid is effectively connected with a permanent establishment or a fixed base situated in the a to get other State , nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State. Article 11 interest 1-interest arising in a Contracting. The State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it «arise and according to the law of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceeds 100 10 per cent of the gross amount of the interest. If the beneficial owner of the interest is a bank or any other financial institution and the interest is paid in connection with a loan granted to another bank or any other financial institution, the tax so charged shall not exceeds 100 5 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 its administrative subdivisions and local authorities, the Central Bank or any financial institution wholly owned by that Government, or interest derived on loans guaranteed by that Government shall be 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, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement. 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 5 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, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial , commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, having regard to the use, right or information for which they are paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement. Article 13 CAPITAL gains 1. Gains derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State or shares in a company the assets of which mainly of such property be consis may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services , including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State operating ships, aircraft or road vehicles in international traffic from the alienation of ships, aircraft or road vehicles operated in international traffic or movable property pertaining to the operation of such ships, aircraft or road vehicles shall be only in taxabl, that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be only in the taxabl Contracting State of which the alienator is a resident. Article 14 independent PERSONAL services 1-income derived by an individual. who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be only in the taxabl you state. But such income may be taxed also in the other Contracting State if: a) the individual has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; but only so much of the income as is attributabl to that fixed base; or (b)) the individual is present in the other Contracting State for a period or periods 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 Contracting State. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Article 15 dependent PERSONAL services 1-subject to the provision of articles 16, 18 and 19, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in the fiscal year concerned , and b the remuneration is paid by), or on behalf of, an employer who is not a resident of the other State, and c the remuneration is not) borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provision of this article, remuneration derived in respect of an employment exercised aboard a ship, aircraft or road vehicle operated in international traffic, may be taxed in the Contracting State of which the enterprise operating such a ship, aircraft or road vehicle is a resident. Article 16 directors ' fees directors ' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. Article 17 artistes AND SPORTSMEN 1. Notwithstanding the provision of articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman's, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsman's in his capacity as such notes to the accru entertainer or sportsman's himself but to another person, that income may, notwithstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman's are exercised. 3. The provision of paragraphs 1 and 2 shall not apply to income derived by a resident of a Contracting State from the activities exercised in the other Contracting State if the visit to that State is wholly or mainly others supported by State funds of one or both of the Contracting States or administrative subdivisions or local authorities thereof, or takes place under a cultural agreement between the Governments of the Contracting States. In such a case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident. Article 18 PENSION subject to the provision of paragraph 2 of article 19, and other similar remuneration paid pension to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. Article 19 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or an administrative 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 others of the similarremuneration shall be only in the taxabl other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State or an administrative subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be only in the taxabl you state. (b) However, such pension shall be) taxabl only in the other Contracting State if the individual is a resident of, and a national of, that State. 3. The provision of articles 15, 16, 17, and 18 shall apply to salar, and other similar remuneration, WAGs and their pension, in respect of services rendered in connection with a business carried on by a Contracting State or an administrative subdivision or a local authority thereof. Article 20 students payments which a student, an apprentice or a trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receive for the purpose of his maintenance, education or training shall not be taxed in that State , provided that such payments «arise from sources outside that State. Article 21 OTHER income 1-items of income. of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Agreement shall be only in the taxabl you state. 2. The provision of paragraph 1 shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 3. Notwithstanding the provision of paragraph 1 and 2 any income in the form of winning from gambling and lotter, arising in the other Contracting State, may be taxed in that also other Contracting State. Article 22 methods FOR ELIMINATION OF double TAXATION 1. In the case of Kyrgyzstan double taxation shall be avoided as follows: (a)) where a resident of Kyrgyzstan's income which, deriv in accordanc with the provision of this agreement, may be taxed in Latvia, Kyrgyzstan 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. The amount of the tax deducted in accordanc with the aforementioned provision shall not exceeds 100 for the tax, which would have been charged to this income by the rates effective in Kyrgyzstan. b) where a resident of Kyrgyzstan's income which in accordanc deriv with the provision of this Agreement shall be only in Latvia, taxabl Kyrgyzstan may include this income in the tax base, but only for the purpose of establishing the tax rate for such income being applicable for taxation in Kyrgyzstan. 2. In the case of Latvia shall be avoided as double taxation follows: a) where a resident of Latvia's income which, deriv in accordanc with this agreement, may be taxed in Kyrgyzstan, 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 Kyrgyzstan. 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 Kyrgyzstan. (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 Kyrgyzstan in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Kyrgyzstan 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. Article 23 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 Contract ting 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, notwithstanding the provision of article 2, apply to taxes of every kind and description. Article 24 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 agreement, 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 23, 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 agreement. 2. The competent authority shall endeavour, if the objection to it appear to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordanc with the agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any doubt arising as to the difficult or is it the interpretation or application of the agreement. They may also consult together for the elimination of double taxation in cases not provided for in the agreement. 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 25 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 agreement or of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or their administrative subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the agreement. The exchange of information is not restricted by articles 1 and 2. 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 referred to in the first line. 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 be construed so as by 1 the ragraph 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 26 members OF DIPLOMATIC missions AND CONSULAR posts Nothing in this Agreement shall be affec the fiscal privilege of members of diplomatic missions or consular posts under the general rules of international law or under the provision of special agreements. Article 27 ENTRY into force 1. The Governments of the Contracting States shall notify each other through diplomatic channels of the completion of the procedure for the bringing into force of this agreement. 2. This agreement shall enter into force on the date of the later of the notifications referred to in paragraph 1 and its provision shall have effect in both Contracting States: a in a) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the agreement enter into force; (b)) in respect of other taxes on income, for taxes chargeabl for any tax year beginning on or after the first day of January in the calendar year next following the year in which the agreement enter into force. Article 28 TERMINATION this Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the agreement, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year. In such event, the agreement shall cease to have effect in both Contract States: a) in ting respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (b)) in respect of other taxes on income, for taxes chargeabl for any tax year 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 the theret, have signed this agreement. Done in duplicate at Bishkek this 7 day of December 2006, in the Latvian, Kyrgyz, Russian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Government of the For the Government of the Republic of Latvia Republic of Kyrgyz Apokin Akylbek Japarov Igor