The Saeima has adopted and the President promulgated the following laws: For the Government of Latvia and the Government of Macedonia agreement on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital article 1. The Government of Latvia and the Government of Macedonia, an agreement on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital (hereinafter referred to as the Treaty) this law is adopted and approved. 2. article. Contractual commitments coordinated by the Ministry of finance. 3. article. The agreement shall enter into force for the period specified in article 28 and the 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 contract in law Latvian and English. The Parliament adopted the law of 29 March 2007. The President of the Parliament instead of the President i. Emsis Riga, 2007 April 18, the Government of LATVIA and the Government of MACEDONIA, an agreement on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital Government of Latvia and the Government of MACEDONIA, reaffirming willingness to conclude an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed the following: 1. the article of the PERSON To which the Treaty applies this Agreement shall apply to persons who have one or both of the Contracting States residents. Article 2 taxes covered by the AGREEMENT. This Agreement shall apply to taxes on income and capital, which is imposed on the Contracting State or of its local authorities, irrespective of the good this kind of taxation. 2. On the income and capital taxes, regarded all taxes imposed on total income, total capital or income or capital, including taxes on the capital gains of the moveable and immovable property seizures, taxes on the total enterprise paid the wages or salary amount and taxes on capital appreciation. 3. The existing taxes to which this agreement applies, in particular, is: (a)) in Macedonia: (i) the individual income tax; (ii) the profit tax; (iii) the property tax; (hereinafter referred to as the Macedonian tax); (b)): (i) corporate income tax; (ii) the individual income tax; (iii) tax on immovable property; (hereinafter-the Latvian tax). 4. This agreement shall also apply to any identical or substantially similar taxes which, supplementing or replacing the existing taxes, will be introduced at the date of signature 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 Agreement): (a) the term "Macedonia" means the territory of the Republic of Macedonia, and, used in a geographical sense, it represents the land, internal waters and its subsoil, over which it has jurisdiction or sovereign rights with respect to natural resource exploration, exploitation, conservation and management under the internal jurisdiction and international law; (b)), the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the laws of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (c) the terms "a Contracting State)" and "the other Contracting State" mean depending on the context of Latvia or Macedonia; (d)) the term "person" means a natural person, company, or any other Association of persons; e the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association; (f) the terms ") of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; (g)) the term "international traffic" means any carriage by sea or air vehicles by the company of a Contracting State, except for the cases when the sea or air transport to move only in the other Contracting State; h) the term "competent authority" means: (i) Macedonia-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 applied at that time 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 domicile, residence, place of incorporation, leadership, location, or any other similar criteria, and also includes the State and any of its municipalities. However, this term does not include those individuals in that State taxes are imposed only in respect of their income from this country to the existing sources of profit or the capital. 2. Where, in accordance with the provisions of part 1 an individual is a resident of both Contracting States, its status would be as follows: (a)) will be considered as the person only as a resident of the State in which they habitually resident; If you are habitually resident in two countries, this person will be considered only for residents of the State, with which it has closer personal and economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it is not a permanent residence in one of the two countries, that person will be considered a resident of the country only, which is its usual home; c) if that person normally home in both countries or none of them, it will be considered only for residents of the country, 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, it will be considered a resident of the State from which the legislation follows the person's status as such. 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; and (f)) mine shaft, oil or gas extraction sites, quarries or any other place of extraction of natural resources. 3. The term "permanent establishment" likewise encompasses: a a building site or construction or) installation project, where the work or the project is going on for more than nine months; b) Contracting State actions associated with this country and its existing sea of subsoils and 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. 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 is in constant the Mission of the country concerned, unless such person has carried out only part 4 for actions that you perform certain actions in place, this particular site in accordance with 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, using only the broker, agent or any other agent of an independent status, provided that such persons perform their normal business activities. 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 agreement, which gives the real estate buying or selling rights or similar right to acquire real estate, the real estate and rights to variable or fixed payments as consideration for the mineral deposits, natural ore and other natural resources, or the right to use , right on the sea and subsoils and to natural resource exploration or use of the property, including the right to participation or benefit from this property. For real estate will not be regarded as sea and air transport. 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, as well as income from the alienation of immovable property. 4.1 and part 3 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. 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, will be allowed to deduct the expenses (other than expenses which would not be deductible if the permanent establishment were a separate country of this Contracting Company), due to the needs of the permanent representation to the country or elsewhere, including operational and general administrative costs. 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 agreement are considered separate income type, this article shall not affect the other provisions of this article. Article 8 shipping and air TRANSPORT 1. Contracting State company profits gained from the sea or air transport use in international traffic 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 are created or established by rules different from those provisions that the force between two independent companies , then any profits which would, but for one of the companies affected by the above provisions did not have, can be included in the company's profits, and it may be appropriate to impose taxes. 2. where a Contracting State includes in the profits of an enterprise of that State and taxes accordingly profits on it, in respect of which no other country in the other Contracting State, the company has been taxed, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, the other country take appropriate adjustment for the size of the tax What are the gains of the other country. In determining this adjustment, take into consideration other provisions of this 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 manage at least 10 percent of the company capital that paid dividends; b) 10 per cent of the total dividends in all other cases. This part shall not affect the taxation of company profits from which dividends. 3. The term "dividends" in this article means income from shares or other rights to participate in profits, not claims, as well as income from other rights, including corporate law, which, in accordance with its national legislation, which the resident is a company that performs the distribution of profits, subject to the same taxation treatment as income from shares. 4. parts 1 and 2 shall not apply if the 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 representations in the other 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. 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, the These percentages can 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 5 percent of the total amount of interest. 3. Notwithstanding the provisions of part 2: a) interest arising in a Contracting State and which is the real owner is the Government of the other Contracting State, its local authorities, central bank or any financial institution wholly owned by that Government, or interest that you pay on the loan, which has given the guarantee that the Government or the local government, the first in that country will be exempt from taxation; b a) interest arising in a Contracting State will be exempt from taxation in that State, if the interest owner is implemented on the territory of the other Contracting State and the interest is paid on the debt obligations that emerged when the second State company sells the former State enterprise production, commercial, or scientific equipment, except when such sales or debt obligations is developed between the related parties. 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. 5.1, 2 and 3 shall 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. 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 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, 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 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: (a)) 10 per cent of total amount of the royalties in the motion picture and film or record the radio or television broadcasts or on the right to use them; b) 5 percent of the total of the royalties in all other cases. 3. The term "royalties" in this article means payments of any kind received as a compensation for the use of any copyright or rights to use any copyright on literary, artistic or scientific work, including cinematograph films and films or recordings for radio and television broadcasting, any patent, trademark, design or model, plan, secret formula or process, or for the production, commercial, or scientific equipment, or for the right to use them , or for information concerning industrial, commercial or scientific experience. 4. 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 that other State through a permanent base located there, and if the right or property for which the royalties are paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the payer of the royalties is a resident of a Contracting State, it 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 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 property, may be subject to taxes in the other country. 2. Capital gains, by a resident of a Contracting State derives, the disposal company shares or other corporate rights, active mainly (more than half) are made from article 6 in the second Contracting State to an existing real property, may be taxed in that other State taxes. 3. Capital gains that accrued, disposing of property, which is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State, or disposing of property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, 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. 4. Capital gains by the public company, which uses the sea or air means of transport in international traffic, shall forfeit the use in international traffic, marine or air transport or disposal of the property, which belongs to the sea or air transport means will be taxable only in that State. 5. Capital gains generated by the disposal of any property that is not 1, 2, 3 and 4, part estate, will be 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-natural persons income, providing professional services or other independent activities, will be taxable only in that State unless that person your actions, uses it regularly available permanent base in the other State. If you are using such a permanent base, the income may be subject to taxes in the other country, but only to the extent that they apply to this permanent base. The application of this article, if a resident of a Contracting State-natural person resident in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any 12 month period commencing or ending in the taxation year will be considered that this person uses regular access to permanent base in the other Contracting State and the income that accrued on the second country made the above actions will be applied to this permanent base. 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 INCOME from employment 1.16, 18 and article 19 of the regulations for the payment of wages and other similar remuneration, to which 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 TRANS port, can impose taxes in the country. Article 16 DIRECTORS ' fees directors ' fees and other similar payments received by a resident of a Contracting State as the Board of directors or the supervisory board member of the society, which is the second resident of the Contracting State 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 1. 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, be taxable only in that State. 2. Notwithstanding paragraph 1 and article 19 of part 2 of the part of the pension and other similar remuneration, which is paid in accordance with the Contracting State social security legislation 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 a local government for this country or services provided to the municipality 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 local authorities or who are paid out of the funds set up for services provided by that person in 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 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 municipality's business. Article 20 students payments which a residence, study or internship needs receives a student 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. Article 21 other income 1. Other income of a resident of a Contracting State which are not stipulated in the preceding articles of this agreement, regardless 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, application of the Treaty article 7 or 14. Article 22 capital 1. Capital represented in article 6 that a resident of a Contracting State of the real estate, which is situated in the other Contracting State may be taxed in that other State taxes. 2. Capital represented by movable property forming part of the Contracting State of the permanent representation of the company business property in the other Contracting State or to capital represented by movable property that belongs to a resident of a Contracting State, to the standing base of independent personal services in the other Contracting State may be taxed in that other State taxes. 3. Capital represented by marine or air transport means that a company of a Contracting State in international traffic are used, as well as movable property belonging to the maritime and air transport, will be taxable only in that State. 4. all other Contracting State, a resident of the capital items will be taxable only in that State. Article 23 avoidance of double taxation in Macedonia 1, double taxation shall be avoided as follows: where a resident of Macedonia derives income or owns capital which, in accordance with this agreement may be subject to taxes in Latvia, then a permit: (a) Macedonia) reduce the resident's income tax for an amount equal to the income tax paid in Latvia; (b) the resident's capital) to reduce tax on an amount equal to the capital tax paid in Latvia. These reductions, however, in no case, exceed the income tax or capital tax, part of what is calculated before this fall and depending on the circumstances, which is attributable to the income or the capital which may impose tax in Latvia. 2. In Latvia, double taxation shall be avoided as follows: (a) where a resident of Latvia) derives income or owns capital which it in accordance with this agreement may be subject to taxes in Macedonia, then, unless national legislation is more favourable provisions, Latvia permission: (i) reduce the resident's income tax for an amount equal to the income tax paid in Macedonia; (ii) reduce the resident's capital tax on amount equal to the capital tax paid in Macedonia. These reductions, however, in no case, exceed the income tax or capital tax, part of which is calculated in Latvia before the application of this reduction and, depending on the circumstances of which is attributable to the income or the capital which may be taxed in Macedonia taxes. (b)) (a) (a) for the application of this paragraph, if society)-a resident of Latvia receives a dividend from a company-resident of Macedonia in which it owns at least 10 percent of shares with full voting rights, the tax paid in Macedonia will include not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the profits of the company out of which the dividend was paid. 3. where in accordance with any provision of this agreement, the Contracting State generated by the resident or his capital is exempt from tax in that State, then in calculating tax on the remaining income of a resident of this State or capital, take into account the exempt income. 24. Article 1 of the prevention of DISCRIMINATION To 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 other citizens of this country. 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. 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, 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 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. Similarly, the enterprise of a Contracting State in the other Contracting State debt residents, establishing this company's taxable capital, is to be deducted by the same rules as if they would apply to the first residents of that State. 5. the Contracting State whose capital, in whole or in part, directly or indirectly, belongs to one or more residents of the other Contracting State or in full or in part, directly or indirectly control these residents, the first State may not be subject to any taxation or any requirements associated with it, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or which is more burdensome for them. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind and name. 25. Article 1 mutual consultation procedures. If a person believes that one or both of the Contracting State party to a national action in relation to this person causes or will cause the taxation which does not comply with the terms of this agreement, 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 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, 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 in 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 26 exchange of information 1. The competent authorities of the Contracting States shall exchange the information necessary for the carrying out of this contract or national legislation requirements on taxes covered by this agreement, insofar as these regulations not inconsistent with this agreement. Article 1 of the agreement shall not preclude 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), which is involved in a tax covered by this agreement, the calculation, collection, use of coercive measures, trials or appeals related to these taxes. Such persons or authorities, this information must be used only for the purposes mentioned above. They may disclose the information in public hearings or in judgements. 2. the provisions of part 1 should not be explained so that they bind the Contracting State the obligation: a to carry out administrative measures), which does not comply with one or other of the contracting national legislation and administrative practice; (b)) to provide information that is not available under one or the other national legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or process technology, or to provide information, the disclosure of which would be contrary to the public interest (ordre public). Article 27 diplomatic and consular personnel, nothing in this Agreement shall affect the diplomatic missions or consular posts personnel fiscal privileges which international law granted the General provisions or special agreements. Article 28 entry into force each Contracting State diplomatic channels must notify the other country that has met its national laws and the procedures necessary for the entry into force of this Treaty. The contract shall enter into force on the date of the last statement, and its provisions in both Contracting States shall be applied: (a)) in respect of taxes withheld at the time the cost-starting with the income for the first day of January or after the first day of January in the calendar year following the year in which this agreement enters into force; (b)) in respect of other taxes on income and capital-from taxes to be paid in any taxation year that begins on the first day of January or after the first day of January in the calendar year following the year in which this agreement enters into force. Article 29 termination this Agreement shall remain in force as long as one Contracting State it shall be terminated. Each Contracting State may terminate this contract, diplomatic channels by giving written notice of termination at least six months before any end of the calendar year following the five-year period from the date of entry into force of the Treaty. In this case, the agreement of both Contracting States shall cease: (a)) in respect of taxes withheld at the time the cost-starting with the income gained in January of the calendar year or after the first day of the calendar year following the year in which the notice of termination; (b)) in the case of other income taxes and capital taxes-from taxes to be paid in any taxation year that begins January of the calendar year or after the first day of the calendar year following the year in which the notice of termination. In witness thereof, the undersigned, being duly authorised, have signed this agreement. The agreement is drawn up in two copies in the 2006 December 8 Latvian, Macedonian and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.  

The Government of LATVIA on behalf of the Government of MACEDONIA Artis Pabriks Antonio Milošosk in the agreement BETWEEN the ENGLISH Government AND the MACEDONIAN Government FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income AND ON CAPITAL the ENGLISH Government AND the MACEDONIAN Government to conclud an agreement (menu rngton Line4) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital , 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 the Andean capital on (a) the Contracting State or of its local authorities, irrespectiv of the manner in which they are levied. 2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovabl property, taxes on the total wage or non of salar to paid by enterprises, as well as taxes on capital appreciation. 3. The existing taxes to which the agreement shall apply to: (a) in particular) in Macedonia: (i) the personal income tax; (ii) the profit tax; (iii) the property tax; (hereinafter referred to as "Macedonian tax"); (b)) in the United Kingdom: (i) the enterprise income tax; (ii) the personal income tax; (iii) the property tax immovabl; (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 which 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) "Macedonia" means the territory of the Republic of Macedonia, and used in the sense of location it means land, inland lake water and bottom over which it has jurisdiction or sovereign rights for the purpose of exploring, exploiting, conserving and managing the natural resources, the internal jurisdiction and pursuan international law; (b)) the term "United States" means the Republic of Latvia and, when used in the sense of location, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the law of Latvia and in accordanc with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub soil and their-natural resources; (c)) the terms "a Contracting State" and "the other Contracting State" mean Latvia or Macedonia, as the context requires; (d) the term "person") includes an individual, a company and any other body of persons; e the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose; (f) the term ") enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; h) the term "competent authority" means: (i) in Macedonia, the Ministry of finance or it's authorised representative; (ii) in Latvia, the Ministry of finance or it's 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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any local authority thereof. This term, however, does not include any person who is liabl to tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provision of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests); (b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State under the law of which it deriv it status as such. 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, and f)) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" of a likewis: encompass) a building site or construction or installation project only if such site or project lasts more than nine months; (b) 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. 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, any agreement granting a right to purchase or sell property immovabl or similar right in respect of property, usufruc immovabl 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, rights to assets to be produced by the exploration or exploitation of the sea bed and sub-soil and their natural resources, including rights to interests in or to the benefit of such assets. Ships and aircraft shall not be regarded as immovabl property. 3. The provision of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovabl property, as well as income from the alienation of property immovabl. 4. The provision of paragraphs 1 and 3 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In determining the profits of a permanent establishment in a Contracting State, there shall be allowed as a deduction in "expense (other than expense of which would not be deductibl if that permanent establishment were a separate enterprise of that Contracting State) which are 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. 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 SHIPPING AND AIR transport 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxabl only in that State. 2. The provision of paragraph 1 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 10 per cent of the capital of the company paying the dividend; b) 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall not be affec the taxation of the company in respect of the profits out of which the dividend is paid with. 3. The term "dividends" as used in this article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other rights, including corporate rights, which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 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 situated in a to that other State , nor subject the company's undistributed profits to a tax on undistributed profits of the company s, 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 5 per cent of the gross amount of the interest. 3. Notwithstanding the provision of paragraph 2: (a) interest arising in a Contracting) State, derived and beneficially owned by the Government of the other Contracting State, including local authorities thereof, the Central Bank or any financial institution wholly owned by that Government, or interest paid in respect of a loan guaranteed by that Government or authority, shall be the main from tax in the first-mentioned State; (b) interest arising in a Contracting) the State shall be the main from tax in that State if the beneficial owner of the interest is an enterprise of the other Contracting State, and the interest is paid with respect to an indebtednes of the consequences arising as of the sale on credit by an enterprise of that other State of industrial, commercial or scientific equipment to an enterprise of the first-mentioned State , except where the sale or indebtednes is between related persons. 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 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: (a) 12 10 per cent) of the gross amount of the paid for the USA to royalt of , or the right to use, cinematograph films and films or tapes for radio or television broadcasting; (b) 5 per cent) of the gross amount of the stay in all other cases royalt. 3. The term "royalt" as used in this article means payments of any kind received as a considerations for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of , or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 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 situ ated therein, or perform in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, having regard to the use, right or information for which they are paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this 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 may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company the assets of which the consis mainly (more than one half) of property referred to in immovabl article 6 and situated in the other Contracting State may be taxed in that other State. 3. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services , including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 4. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be only in the taxabl you state. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxabl only in the Contracting State of which the alienator is a resident. Article 14 independent PERSONAL services 1-income derived by an individual. who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxabl only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other State but only so much of it as is attributabl to that fixed base. For this purpose, where an individual who is a resident of a Contracting State stay in the other State for a period or Contracting period exceeding in the aggregate 183 days in any twelve month period commencing in or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to above that are performed in that other State shall be attributabl to that fixed base. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Article 15 income FROM employment 1. Subject to the provision of articles 16, 18 and 19, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in the fiscal year concerned , and b the remuneration is paid by), or on behalf of, an employer who is not a resident of the other State, and c the remuneration is not) borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provision of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State. Article 16 DIRECTOR's fees Director's fees and other similar pay proposals derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board of a company which is a resident of the other Contracting State may be taxed in that other State. Article 17 artistes AND SPORTSMEN 1. Notwithstanding the provision of articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman's, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsman's in his capacity as such notes to the accru entertainer or sportsman's himself but to another person, that income may, not withstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman's are exercised. 3. The provision of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsman's if the visit to that State is wholly or mainly supported by public funds of one or both of the Contracting States or local authorities thereof. In such case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident. Article 18 PENSION 1. Subject to the provision of paragraph 2 of article 19, and other similar remuneration paid pension to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. 2. Notwithstanding the provision of paragraph 1 of this article and paragraph 2 of article 19, and other similar remuneration paid at pension under the social security legislation of a Contracting State 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 local authority thereof to an individual in respect of services rendered to that State or authority shall be only in the taxabl you state. (b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or authority shall be only in the taxabl you state. (b) However, such pension shall be) taxabl only in the other Contracting State if the individual is a resident of, and a national of, that State. 3. The provision of articles 15, 16, 17 and 18 shall apply to salar, and other similar remuneration, WAGs and their pension, in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof. Article 20 students payments which a student or business apprentice 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. Article 22 CAPITAL 1. Capital represented by immovabl property referred to in article 6, owned by a resident of a Contracting State and situ ated in the other Contracting State, may be taxed in that other State. 2. Capital represented by 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 by 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, may be taxed in that other State. 3. Capital represented by ships or aircraft operated in international traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships and aircraft, shall be only in the taxabl you state. 4. All other elements of capital of a resident of a Contracting State shall be only in the taxabl you state. Article 23 ELIMINATION OF double TAXATION 1. In the double taxation shall be Macedonia eliminated as follows: where a resident of Macedonia income or of deriv own capital which, in accordanc with the provision of this agreement may be taxed in Latvia, Macedonia shall allow: a as a deduction in ") from the tax on the income of that resident, an amount equal to the income tax paid in Latvia; (b)) as a tax on capital from the marbles of that resident, an amount equal to the capital tax paid in Latvia. Such a deduction in "in either case shall not, however, that about 12 of the income tax or capital tax, as computed before the deduction in" is given, which is attributabl, as the case may be, to the income or the capital which may be taxed in the United Kingdom. 2. In Latvia the double taxation shall be eliminated as follows: a where a resident of) Corporation's deriv income or own capital which, in accordanc with this agreement, may be taxed in Macedonia, unless a more favourabl treatment is provided in its domestic law, Latvia shall allow: (i) as a deduction in "from the tax on the income of that resident, an amount equal to the income tax paid thereon in Macedonia; (ii) as a deduction in "from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in Macedonia. Such marbles in either case shall not, however, that about 12 of the income tax or capital tax in Latvia, as computed before the deduction in "is given, which is attributabl, as the case may be, to the income or the capital which may be taxed in Macedonia. (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 Macedonia in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Macedonia 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. 3. Where in accordanc with any provision of the agreement income derived or capital owned 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 or capital of such resident, take into account the exempted income or capital. 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. Similarly, any debt of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the capital of the taxabl such enterprise, be-deductibl under the same conditions as if they had been contracted to a resident of the first-mentioned State. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensom than the taxation and connected requirements to which other similar enterprises of the first-mentioned State may be subjected to or. 6. The provision of this article shall, not withstanding 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 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 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 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 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 agreement or of the domestic laws of the Contracting States concerning taxes covered by the agreement insofar as the taxation thereunder is not contrary to the agreement. 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 agreement. 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 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 28 ENTRY into force 1. Each of the Contracting States shall notify to the other, through diplomatic channels, the completion of the procedures required by its law for the bringing domestics into force of this agreement. This agreement shall enter into force on the date of the later of the notifications 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 and on capital, for taxes for any fiscal year beginning chargeabl on or after the first day of January in the calendar year next following the year in which this agreement enter into force. Article 29 TERMINATION this Agreement shall remain in force until terminated by one of the Contracting States. 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 following after a period of five years from the date on which the agreement enter into force. In such event, the agreement shall cease to have effect in both Contracting States: a in respect of taxes) withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (b)) in respect of other taxes on income and on capital, for taxes for any fiscal year beginning chargeabl on or after the first day of January in the calendar year next following the year in which the notice has been given. In witness whereof, the undersigned, duly authorised by the the theret have signed this agreement. Done in duplicate at Riga, this 8th day of December 2006 in the Latvian, Macedonian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation, the English text shall prevails.  

For The ENGLISH Government FOR The MACEDONIAN Government Artis Pabriks Antonio Milososk In