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

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

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The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Government of the Republic of Slovenia to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital article 1. 2002. on 17 April, Ljubljana signed by the Government of the Republic of Latvia and the Government of the Republic of Slovenia the Convention on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter the Convention) and its 2002 17 April, Ljubljana signed a Protocol (hereinafter referred to as the Protocol) with this law is adopted and approved. 2. article. The law shall enter into force on the date of its promulgation. With the law put the Convention and Protocol in English and Latvian. 3. article. The Convention and the Protocol shall enter into force the Convention article 29 within the time and in order, and the Ministry of Foreign Affairs shall notify the newspaper "journal". The Parliament adopted the law of 24 October. State v. President Vaira Vīķe-Freiberga in Riga 2002 November 8 the Government of the Republic of LATVIA and the Government of the Republic of SLOVENIA the Convention on avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital the Government of the Republic of Latvia and the Government of the Republic of Slovenia, reaffirming willingness to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, agree: article 1 persons covered this CONVENTION shall apply to persons Convention that is one or both of the Contracting State party to the country resident. Article 2 taxes covered by the CONVENTION (1) this Convention shall apply to taxes on income and capital, charged by the Contracting State or of its political or administrative units of the municipal well, regardless of the method of collecting the tax. 2. On the income and capital taxes, regarded as all taxes, which puts the total income total capital or income or capital, the tax shall be levied with movable or immovable property alienation in earned income and capital appreciation. 3. The existing taxes to which this Convention applies, in particular, is: (a)) Slovenia: (i) the legal person of profit tax (davek od dobick pravnih oseb in); (ii) tax that taxed the income of natural persons, including salary, wages, income from agricultural activities, from business, from capital gains and real and movable property (dohodnin); (iii) the property tax (davek na premozenj); (iv) the special tax, which taxed the resources of banks and savings banks (davek na posebn in bilancn in hranilnic the bank of vsot); (hereinafter referred to as the Slovenian tax); (b)): (i) corporate income tax; (ii) the individual income tax; (iii) tax on immovable property; (hereinafter referred to as the Latvian tax). 4. this Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of this Convention is to supplement or replace the existing taxes. Both the competent authorities of the Contracting States inform each other of any significant amendments to the national legislation of the relevant tax legislation. Article 3 General definitions 1. If it is not apparent from the context, otherwise in this Convention: a the term "Slovenia") means the Republic of Slovenia, and used in a geographical sense, it represents the territory of Slovenia, including the territorial sea adjacent to the sea, the sea and the Earth, where, in accordance with domestic law and international law, Slovenia over such sea, land and sea depths may exercise its sovereign rights and jurisdiction; (b)) the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial sea adjacent territory in accordance with Latvian law and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (c) the term "Contracting State)" and "the other Contracting State" mean, depending on context or Latvia Slovenia; (d) the term "person") means a natural person, company, or any other Association of persons; e the term "company") shall mean any corporate person, association or any entity, which, for the purposes of taxation is considered a corporate Association of persons; (f) the term "Contracting Government) of the enterprise" and "enterprise of the other Contracting State" mean respectively an enterprise run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; g) the term "international traffic" means any carriage by sea or air, by a 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) in Slovenia: the Ministry of Finance of the Republic of Slovenia 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 that determines the status of a Contracting State to the existing legislation. 2. for the application of this Convention at any time Contracting State will use any term which is not defined here, if not apparent from the context, otherwise only in the sense in which it is applied at the time the legislation of a Contracting State concerning the taxes to which this Convention applies, in addition, any explanation of the term in accordance with applicable tax law will have precedence over this explanation of the concept of this national legislation. Article 4 resident 1. In this Convention, the term "resident of a Contracting State" means any person who, in accordance with the national legislation is subject to taxation on the basis of the place of residence, residence, location management, place of incorporation (registration) or under any other criteria like this, and also includes that State, its political-administrative unit or municipality. However, this term does not include those individuals in this country is taxable only in relation to their income from this country to the existing sources of profits or capital located there. 2. Where, in accordance with this the provisions of paragraph 1 of article of a person is a resident of both Contracting States, its status will be determined as follows: (a)) this person will be considered a resident only of the State in which it has its habitual residence; 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 only for residents of the State that it is customary in the 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 paragraph 1 of this article the provisions a person who is not a natural person, is a resident of both Contracting States, the competent authorities must seek to resolve the matter by mutual agreement. In the absence of such agreement, the application of this Convention, that person will not be entitled to claim any tax relief or exemption from taxes, granted in accordance with this Convention. Article 5 permanent establishment 1. In this Convention, the term "permanent establishment" means a fixed place of business of which is wholly or partly carried on business. 2. The term "permanent establishment" includes: (a) the management of the company); b) branch; c) Office; (d) a factory;) e a workshop, and f)) mine shaft, oil or gas extraction sites, quarries or any other place of extraction of natural resources. 3. a building site, a construction,) the Assembly or installation project or supervisory activities associated with them will be considered permanent representation only if these works, project or activity occurs for more than nine months; (b) Contracting State) shelf area, associated with the State of the sea and of the subsoils and there existing natural resource exploration and exploitation, are considered the actions taken in this country, using existing permanent representations, if this activity lasts for a period or periods that in total exceed 30 days in any 12-month period. 4. Notwithstanding the preceding paragraphs of this article, the provisions of 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) permanent site for business purposes only and only for purchase of the goods or products or information gathering; e) permanent site designed solely to make business arrangements or any other ancillary; f) permanent site designed solely to deal with (a)) and (e)) the following, in any combination thereof, if the total activity is preparatory or auxiliary character. 5. Notwithstanding paragraph 1 and paragraph 2, where a person who is not in this article the status of independent agent, running your business, and it is empowered to enter into contracts on behalf of the company, and the State typically used these powers, then it is considered that this company used permanent representation in that Contracting State in respect of any of the person's business activities except when he is carrying out the activities referred to in paragraph 4, which, in the event of a permanent place of business cannot be considered permanent representation in accordance with paragraph 4 of this article. 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 the company is a resident of a Contracting State-controlled company that is a resident of the other Contracting State, or which carries on business in that other State through a permanent establishment or in any other way, or is subject to the control of such undertaking itself does not turn into one of those companies on the other company's permanent representation. 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 taxing in that other country. 2. the term "immovable property" have the meaning it has in its legislation of a Contracting State in which the property is located. In any case, this concept includes property which belongs to real estate property, livestock and equipment used in agriculture and forestry, rights to which the General legislative acts are attributable to the ground attached to the property, any property purchase right of use or similar right to acquire real estate, uzufrukt real estate and rights to variable or fixed payments for the right to use valid, natural mineral deposits and other natural resources, or for the use thereof , the right to property, which can be generated through the sea and subsoils and there existing natural resource exploration or use, including the right to participation in the ownership or profit to be gained in this property. For real estate will not be considered to be vessels and aircraft. 3. paragraph 1 of this article, the rules will be applied in respect of income from real estate direct use, letting or use in any other way. 4. If the company's shares or other corporate rights in a company gives the owner the right to public use of the property, the income from the direct use, letting or use in any other way can be taxing in the Contracting State in which the immovable is situated property. 5. the following article 1, 3, and 4. the provisions of paragraph 1 shall be applied in respect of 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 will be taxed 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 can be taxing in the other country, but only the profit that can be attributed to the permanent establishment. However, the profit gained by the sale of goods or products that are the same or similar to the goods or products that are sold through the permanent representation, or profit that is being made about the other business that is the same or is similar to what is done through permanent representations, can be considered to be attributable to the permanent representations, if it is established that sale or business have been organized in such a way as to avoid paying taxes in the country in which the permanent establishment is situated. 2. in accordance with paragraph 3 of this article, when a company of a Contracting State carries on business in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the amount of profit, it would benefit if the individual is clearly the company that performs the same or similar business activities under the same or similar conditions and acts completely independently of the undertaking, which uses the permanent representations. 3. in determining the profits of a permanent representation in that Contracting State be allowed permanent representation expenses, including representation of operational and general administrative costs incurred by the country in which the permanent establishment or elsewhere, the deduction of the amount of taxable. Expenses that Contracting State allowed to deduct, does not include the expenses of the permanent representation should not be permitted to deduct, if it were a separate enterprise of that Contracting State. 4. where a Contracting State to the permanent representation of the profits determined by dividing the company's total profit in proportion between its departments, this article does not prohibit the Contracting State as usual to determine the taxable profit by this principle; However, this allocation method applicable to the result match the principles contained in this article. 5. On the permanent representation will not be applied the earnings of the mere fact that this representation has purchased the goods or products to your company's needs. 6. for the purposes of applying the provisions of the preceding paragraph, the profits attributed to the permanent representations, each year is determined by the same method, except if there is sufficient reason to do otherwise. 7. If the profit is included in the other articles of this Convention see income separately, this article shall not affect the other provisions of this article. Article 8 shipping and air TRANSPORT 1. Contracting State company profits from the sea or air transport use in international traffic will be taxed only in the country. 2. paragraph 1 of this article, the rules also apply to profits from the participation in a pool, joint business or international traffic transport agency. Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participating in the other Contracting State, the company's management or control or it owns part of the company's capital, or b) the same persons directly or indirectly participating in the management company of a Contracting State or control or they own in the company's capital and at the same time they are directly or indirectly participating in the other Contracting State, the company's management or control or they own part of the company of the other country and in any of these cases, the two companies ' commercial and financial relations are created or established by the rules, which differ from those which would be in force between the two independent (non-related) companies, then any profit that the formation of one of the companies, but the above provisions do not affect the established, can be included in the company's earnings and taxed accordingly. 2. where a Contracting State includes in the profits of an enterprise of that State (and accordingly taxable) profit for which other country in the territory of the other Contracting State has been charged with duties, 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 enterprises had been those between two independent companies, the competent authorities of the Contracting States may hold joint consultations to adjust the size of the tax, which taxed the earnings of both countries. 3. a Contracting State may not adjust the company's profits the conditions referred to in paragraph 1 of its internal legislation, the end of the statutory period and, in any case, five years after the end of the year in which the enterprise of a Contracting State would have built up the profit that would have to be adjusted. This paragraph shall not apply to cases of fraud or wilful default of the obligation. Article 10 dividends 1-dividends, a company of a Contracting State a resident of the other Contracting State paid to a resident, can be taxing in that other country. 2. However, such dividends may also be taxing in accordance with the national law 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 the true owner of the dividends is a company that manages at least 25 percent of the company capital, which paid dividends; b) 15 per cent of the total of dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividend is paid. 3. The term "dividends" in this article means income from shares or other rights to participate in profits, which is not claims, as well as income from other rights which, in accordance with its national legislation, which the resident is a company that carries out the distribution of profits, is subject to the same taxation as income from the shares. 4. the following article 1 and paragraph 2 shall not apply if the rightful owner of dividends, which is a resident of a Contracting State, carries on business in the other Contracting State of which the resident is a company that paid dividends, with the existing permanent representation there, or give independent individual services in that other State through a permanent base located there, and where participation, which is paid out in dividends, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the company — a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not be nor to any tax the dividends paid, except if the dividends are paid to a resident of the other State, or when the participation of which is paid out in dividends, is actually related to the permanent representation or permanent base, located in the other State; nor to retained earnings in the company's undistributed profits, 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 taxing in that other country. 2. However, such interest may also be taxing according to national law the Contracting State in which they arise, but, if the interest owner is implemented on the territory of the other Contracting State, a resident of the tax must not exceed 10 percent of the total amount of interest. 3. Notwithstanding the provisions of paragraph 2 interest arising in a Contracting State and one where the recipient and the rightful owner is the territory of the other Contracting State Government, including the municipal and political and administrative units, the central bank, public joint stock company "Latvijas eksportkredīt", Slovene export company (Slovenska izvozn a druzb) as well as the interest received on the "eksportkredīt" or Slovenian export loans guaranteed by the company, will not be taxed in the first country. 4. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage and 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 any income which is treated as a dividend under the provisions of article 10. Interest received on payments made during, not be regarded as interest for the application of the provisions of this article. 5. the following article 1, paragraph 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 therein, and of claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 6. If the payer of the interest is a resident of a Contracting State, it 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 the debt that pays interest, and this 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, on the basis of 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. The remaining part of the payment is tax deductible according to each Contracting State law provided that you comply with the other provisions of this Convention. Article 12 ROYALTIES (1) royalties arising in a Contracting State and paid to a resident of the other Contracting State, may be taxing in that other country. 2. However, such royalties may also be taxing in accordance with national law of the Contracting State in which it arises, but if the true owner of the royalties is a resident of the other Contracting State, the tax shall not exceed 10 per cent of the gross amount of such royalties. 3. The term "royalties" in this article means payments of any kind received as a compensation for the use of any copyright or rights to use any copyright on literary, artistic or scientific work, including cinematograph films and films or records, or other image or sound reproduction features 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. the following article 1 and 2 of the terms will not apply, if the true owner of the royalties, who 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 in respect of which the royalties are paid is actually related to this permanent representation or permanent 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, which committed to pay the royalties, and the royalties paid to (bear) permanent establishment or fixed base, will be considered that the royalties arise in the State in which the permanent establishment or fixed base. 6. If, on the basis of the special relationship between the payer 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 the royalties are 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 part of the payment that exceeds this amount, you will be taxed according to each Contracting State law provided that you comply with the other provisions of this Convention. Article 13 capital gains 1. Capital gains, by a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real estate or shares of one company, the property of which consist mainly of such property can be taxing in that other country. 2. Capital gains derived from the property, which is an enterprise of a Contracting State in the other Contracting standing representative offices in the country to be used in the business part of the property, or from the disposition 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 the disposition of the capital gains gained from such permanent missions (alone or with the whole enterprise) or of such a permanent disposal base disposal can be taxing in the other Contracting State. 3. Capital increase by the company of a Contracting State in international traffic, which uses the sea or air transport, making international traffic used for sea or air transport or disposal of this marine or air transport use of movable property belonging to the forfeiture, will be subject to tax only in the country. 4. Capital gain that accrued, disposes of any property that differs from the 1, 2, and 3. the property referred to in paragraph 1 will be subject to tax only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. Contracting State residents — physical persons income earned by providing professional services or other independent activities, will be taxed only in the country, except if that person needs their activities using it regularly available permanent base in the other State. If you are using the following permanent base, income can be taxing 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: a 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 that begins or ends in the tax year concerned, shall be considered that this person uses regular access to permanent base the second 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 dependent personal services 1.16, 18, 19 and 20 article, salaries, wages and other similar remuneration which a resident of a Contracting State receives for gainful employment, will be taxed only in the country, if one 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 be taxing in that other country. 2. Notwithstanding paragraph 1 of this article, the provisions of which a resident of a Contracting State receives for paid work that is performed in the other Contracting State, be taxed in the first only in that country, provided that: (a)) is a beneficiary in another country for a period or periods not exceeding in the aggregate 183 days in any 12-month period that begins or ends in the tax year; and (b) the remuneration is paid) an employer who is not a resident of the other State, or the name of the employer; and (c) the remuneration is not paid) (bear) permanent representation or permanent base, used by the employer in the other country. 3. Notwithstanding the preceding paragraphs of this article, the rules of remuneration received for paid work that is being done to a company of a Contracting State in international traffic used for sea or air transport, can be taxing in that Contracting State. Article 16 DIRECTORS ' fees directors ' fees and other similar payments or compensation 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 residents of a Contracting State, may be taxing in that other country. Article 17 artists and athletes 1. articles 14 and 15 of the rules of income for the residents of a Contracting State as izpildītājmāksliniek, such as theatre, film, radio or television, an actor, a musician, or as an athlete on their individual activities in the other Contracting State, may be taxing in that other country. 2. If an artist or athlete's income on his individual activity in the area in question is paid not the artist or athlete but to another person, that income regardless of the 7, 14 and 15 article the rules can be taxing the Contracting State to which the izpildītājmāksliniek or athletes. 3. the following article 1 and paragraph 2 shall not apply to income derived from activities performed by a Contracting State or an athlete, an artist if the visit to that State is wholly or mainly provide support from one or both of the Contracting States, or a political-administrative unit of local government public funds. In this case the income is liable to tax only in the Contracting State of which the resident is the artist or athlete. Article 18 pensions in accordance with article 19, paragraph 2 of the pensions and other similar remuneration received by a resident of a Contracting State for previous paid employment will be taxed only in the country where residents have a pension or a beneficiary. Article 19 government service 1 a) salary, wage and other similar remuneration, other than a pension, which is paid to a natural person contracting State, a political or administrative unit of local government for this country, unit, or for the services provided to the municipality, will be taxed only in the country; (b)) However, this salary, wages and other similar remuneration will be taxed 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 pension by) any natural person the cost of Contracting State, a political or administrative unit of local government or which is paid from the funds set up for services provided by that person in that State, or local government entity will be taxed only in the country; (b)) However, this pension will be taxed only in the other Contracting State if the individual is a resident of that other State and the citizen. 3. This Convention 15, 16, 17 and 18, the provisions of the article apply to wages, salaries, other remuneration and pensions, similar to the paid for services provided in respect of the Contracting State, a political or administrative unit of local business. Article 20 professors and researchers 1. income, on teaching or research work shall receive physical person entering the Contracting State to teach or deal with the research work of the University, college or other recognized that Contracting State educational establishment, and who is, or immediately before the arrival of the State was the territory of the other Contracting State, a resident will not be taxed in the State in the first two years of the date on When this first came to the State above. 2. paragraph 1 of this article shall not be applied to the income generated for research if the research work has been carried out, rather than public interests, but mostly a private person or persons of interest. Article 21 students payments which 1 residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State and who is a resident of the first-mentioned State solely for the purpose of study or internship will not be taxed in that State provided that such payments arise outside that State. 2. For payments that are not defined in paragraph 1 of this article, remuneration in respect of dependent personal services that a student, apprentice or trainee supplied such study or internship period, the student, apprentice or trainee is entitled to the same tax exemptions, incentives or reductions, which are available to residents of the Contracting State which he is visiting for the purpose of study or internship. Article 22 other income 1. other previous articles of this Convention, not those of a resident of a Contracting State income types regardless of their sources will be taxed only in the country. 2. paragraph 1 of this article shall not apply to income, other than income from article 6 paragraph 2 defines the immovable 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 linked to the permanent representations, or permanent base. In this case, depending on the circumstances of this Convention article 7 or 14. Article 23 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 taxing in that other country. 2. capital represented by movable property forming part of the other Contracting State, the Contracting State the company's permanent representation in business-use property or capital represented by movable property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which is used for independent personal services, may be taxing in that other country. 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 or air transport use will be subject to tax only in the country. 4. All the other Contracting State, a resident of the capital items will be taxed only in the country. Article 24 double tax methods of double taxation will be avoided as follows: 1. Slovenia: a) If a resident of Slovenia derives income or owns capital which, in accordance with the provisions of this Convention can be taxing in Latvia, Slovenia must be authorised: (i) reduce the resident's income tax on the portion of the tax is equal to the income tax paid in Latvia; (ii) reduce the capital residents a tax on that portion of the tax is equal to the capital tax paid in Latvia. These reductions, however, in no case, exceed the income tax or capital tax, part of which is calculated in Latvia before this fall and depending on the circumstances, which is attributable to the income or the capital which can be taxing in Latvia; (b)) If, in accordance with any of the provisions of this Convention a resident of Slovenia gained income, or capital he holds is exempt from taxation in Slovenia, Slovenia, then in calculating the duty for the remainder of the income whether the residents of the capital, may also be taken to income or capital which are exempt from taxation. 2. Latvia: a) If a resident of Latvia derives income or owns capital which, in accordance with the provisions of this Convention can be taxing in Slovenia, and if the internal law of Latvia do not provide more favourable provisions, Latvia must permit: (i) reduce the resident's income tax on the portion of the tax is equal to the income tax paid in Slovenia; (ii) reduce the capital residents a tax on that portion of the tax is equal to the capital tax paid in Slovenia. 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 can be taxing in Slovenia;; (b)) (a) for the application of this section, if the company) — a resident of Latvia receives a dividend from a company resident in Slovenia and in the Latvian resident company holds at least 10 percent of shares with full voting rights, the tax paid in Slovenia be included not only the tax charged on dividends, but also those dividends according to the part of the tax charged on the profits of the company out of which the dividend is paid. 25. Article 1 of the Prevention of discrimination of nationals of the other Contracting State, the Contracting State shall not be subject to any taxation or any requirements connected with them, which is different from taxation or related requirements, which are or may be exposed to the other citizens of the country in the same circumstances, or which is more burdensome, in particular with respect to residence. 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 who are residents of a Contracting State, any of the Contracting States shall not be subject to taxation or any related requirements, which differ from the taxation or related requirements, which are or may be exposed to nationals in the same circumstances, or which is more burdensome, in particular with respect to residence. 3. a Contracting State a permanent establishment of the representation used in the other Contracting State may not be taxing in that other country less favourably than would be taxed in the other State companies that do the same type of action. This provision shall not be interpreted so that it would impose a Contracting State the obligation to grant the other Contracting State, a resident of any personal allowances, reliefs and reductions for taxation, as this country give its residents, in the light of their civil status or family responsibilities. 4. Except where the applicable paragraph 1 of article 9, paragraph 7 of article 11, or paragraph 6 of article 12 apply, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident by establishing this company's taxable profits, must be deducted from the profit upon the same terms as if they were to be paid to the first residents of that 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 of the other Contracting State residents or which they directly or indirectly control, the first in that country may not be subject to any taxation or any requirements connected with them, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises, or which are more onerous. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind and name. Article 26 mutual conciliation procedure 1. If a person believes that one or both of the Contracting States party to the cause or may cause that person such taxation, which does not comply with the provisions of this Convention, that person may, irrespective of the national legislative provisions which provide to eliminate such taxation, to submit complaints to the competent authorities of the country of which that person is resident, or if the complaint relates to article 25 (1) of the by the competent authorities of the country of which that person is. The complaint shall be submitted for review within three years of the first notification of the action which led to the provisions of this Convention an inappropriate taxation. 2. the competent authorities are obliged to seek to resolve this issue, if it considers that the complaint is justified, and if this institution fail to reach a satisfactory solution, it should try to solve the question by mutual agreement with the other Contracting State, the competent authorities in order to prevent this Convention without the appropriate taxation. Any such agreement is reached is due irrespective of the Contracting State of the domestic laws of 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 Convention. They may also consult to avoid double taxation in cases not provided for in the Convention. 4. in order to reach agreement on these issues in the previous paragraphs, the competent authorities of the Contracting States may communicate directly with one another, as well as following an exchange of views can take place with the competent authorities of the Contracting States of the representatives of the Commission. Article 27 Exchange of information 1. National authorities should exchange information, which necessary for the carrying out of the provisions of this Convention or of the domestic legislation of the Contracting States for enforcement of legislation on taxes covered by this Convention, in so far as such legislation is not contrary to this Convention. Article 1 of the Convention does not restrict the exchange of information. Any information received by a Contracting State, should be treated as sensitive as information that is obtained in accordance with the national legislation and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the tax to which this Convention applies in calculating, collecting, as well as prosecution of legal liability, or in the application of coercive measures in appeals in respect of those taxes. Such persons or authorities, this information must be used only for the purposes mentioned above. They may disclose the information in public court proceedings or in judgements. 2. paragraph 1 of this article shall not be interpreted 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 other of the Contracting State legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to the public interest (ordre public). Article 28 diplomatic and consular personnel, nothing in this Convention shall not affect the diplomatic missions or consular posts personnel fiscal privileges which it applied in accordance with international law or special agreements. Article 29 entry into force 1. Contracting Governments shall notify each other that the countries have met the constitutional requirements necessary for the entry into force of the Convention. 2. this Convention shall enter into force 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 cost, starting with income earned in January of the calendar year or after the first day of the calendar year following the year in which this Convention enters into force; (b)) in respect of other taxes on income and capital, starting with taxes payable in any tax year, which begins in January of the calendar year or after the first day of the calendar year following the year in which this Convention enters into force. Article 30 termination this Convention shall remain valid as long as the one Contracting State it shall be terminated. Each Contracting State may terminate this Convention, diplomatic channels by giving written notice of termination at least six months before any end of the calendar year. In this case the Convention in both Contracting States: a in the event of termination: (a)) in respect of taxes withheld at the time cost, starting with income earned 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 respect of other taxes on income and capital, starting with taxes payable in any tax year, which begins in January of the calendar year or after the first day of the calendar year in which the notice of termination. In witness thereof, the undersigned, being duly authorised, have signed this Convention. The Convention is drawn up in two copies in the Ljubljana 2002 17 April, Latvian, Slovenian and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.

The Government of the Republic of Latvia, the Republic of Slovenia on behalf of the Government of Maris Riekstins Darko Končan Protocol Signed by the Government of the Republic of Latvia and the Government of the Republic of Slovenia to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital (hereinafter referred to as the Convention), the two parties have agreed upon the following provisions, which shall form an integral part of the Convention. 1. in relation to article 4, paragraph 3 If the person is not a natural person, is a resident of both Contracting States, and the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the status of travel, the competent authorities should take into account such factors as the location of the actual management, incorporation or place of establishment and any other important factors. 2. with regard to article 6 and 13 it is understood that all income and capital gains from that in article 6 real estate located in the other Contracting State, the seizures can be taxing in accordance with the provisions of article 13. In witness thereof, the undersigned, being duly authorised, have signed this Protocol. The Protocol is drawn up in two copies in the Ljubljana 2002 17 April, Latvian, Slovenian and English, in addition, all three texts being equally authentic. Different case is decisive for the interpretation of the text in English.

The Government of the Republic of Latvia, the Republic of Slovenia on behalf of the Government of Maris Riekstins Darko Končan CONVENTION BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the REPUBLIC OF Slovenia FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income AND ON CAPITAL the Government of the Republic of Latvia and the Government of the Republic of Slovenia To conclud a Convention (menu Rngton Line4), for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows: article 1 PERSONS COVERED this Convention shall apply to persons who are residents of one or both of the Contracting States. Article 22 TAX COVERED 1. This Convention shall apply to taxes on income imposed on behalf of the Andean capital on (a) the Contracting State or of its political subdivisions or local authorities, irrespectiv of the manner in which they are levied. 2. There shall be regarded as taxes on income 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, as well as taxes on capital appreciation. 3. The existing taxes to which the Convention shall apply to the in particular: (a)) in Slovenia: (i) the tax on profits of legal persons (davek od dobick pravnih oseb in); (ii) the tax on the income of the individual, including Waga and salar, income from agricultural activities, income from business, capital gains and income from immovabl and movable property (dohodnin); (iii) the tax on property (davek na premozenj); (iv) the special tax on the assets of the bank and savings bank (davek na bilancn posebn in the hranilnic the bank in vsot); (hereinafter referred to as "Slovenian tax"); (b)) in the United Kingdom: (i) the enterprise income tax (corporate income tax); (ii) the personal income tax (individual income tax); (iii) the immovabl property tax (estate tax); (hereinafter referred to as "Latvian tax"). 4. The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify the other of any each significant changes which have been made in their taxation laws of respectiv. Article 3 GENERAL DEFINITION 1. For the purpose of this Convention, unless the context otherwise requires: a the term) "Slovenia" means the Republic of Slovenia and when used in a location sense, means the territory of Slovenia, including the sea area, sea bed and sub-soil adjacent to the territorial sea, if Slovenia may exercise its sovereign rights and jurisdiction over such sea area , sea bed and sub-soil in accordanc with its domestic legislation and 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 sea 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 Slovenia, 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 Slovenia, the Ministry of Finance of the Republic of Slovenia or its authorized representative; (ii) in Latvia, the Ministry of finance or its authorized 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 Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purpose of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State. Article 4 resident 1. For the purpose of this Convention, the term "resident of a Contracting State" means any person who, under the law of that State, is liabl to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liabl to tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provision of paragraph 1 of this article an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests); (b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 of this article a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to the settle the question it by mutual agreement. In the absence of such agreement, for the purpose of the Convention, the person shall not be entitled to claim any benefits provided by this Convention. Article 5 permanent establishment 1. For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a a place of management); (b)) a branch; c) an Office; (d) a factory;) e a workshop, and f)) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. a building site, a) A construction, assembly or installation project or a supervisory activity connected therewith constitut a permanent establishment only if such site, project or activity lasts for a period more than nine months. b) activities carried on offshore in a Contracting State in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that State shall be deemed to be carried on through a permanent establishment 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 subparagraph (a)) (e)), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. Notwithstanding the provision of paragraph 1 and 2 of this article, where a person-other than an agent of an independent status to whom paragraph 6 of this article applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak- for the enterprise, unless the activities of such person with limited it to those mentioned in paragraph 4 of this article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other. Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of general law respecting landed property apply, any option or similar right to the immovabl property, usufruc acquir of immovabl property and rights to variable or fixed payments as considerations for the working of, or the right to work , mineral deposits, sources and other natural resources, 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 of this article shall apply to income derived from the direct use, letting, or use in any other form of immovabl property. 4. Where the ownership of shares or other 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 of this article shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. However, profits derived from the sale of goods or merchandise of the same or similar kind as those sold, or from other business activities of the same or similar kind as those effected, through that permanent establishment may be considered attributabl to that permanent establishment if it is established that such sales or activities were structured in a manner intended to avoid taxation in the State where the permanent establishment is situated. 2. Subject to the provision of paragraph 3 of this article, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment 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 of this article shall preclud that Contracting State from determining the profits to be taxed by such an apportionmen as may be customary; the method of apportionmen, however, the adopted shall be such that the result shall be in accordanc with the principles led in this article. 5. From the profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which the deal with separately in other articles of this Convention, then the provision of those articles shall not be affected by the provision of this article. Article 8 SHIPPING AND AIR transport 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxabl only in that State. 2. The provision of paragraph 1 of this article shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Article 9 ASSOCIATED enterprises 1. Where (a) an enterprise of a Contracting) State of directly or indirectly participat in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons directly or indirectly the participat in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State , and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State — and taxes accordingly — profits on which an enterprise of the other Contracting State a 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 the competent authorities of the Contracting a State may consult together with a view to reach an agreement on the adjustments of profits in both Contracting States. 3. A Contracting State shall not change the profits of an enterprise in the referred to in paragraph 1 of circumstanc of this article after the expiry of the time limits provided in its national laws and, in any case, after five years from the end of the year in which the profits which would be subject to such change would have accrued to an enterprise of that State. This paragraph shall not apply in the case of fraud or wilful default. 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 which holds directly at least 25 per cent of the capital of the company paying the dividend; b) 15 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 which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 of this article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State or of deriv profits income from the other Contracting State, that other State may not impost any tax on the dividends paid by the company, except insofar as such dividends to be paid to a resident of that other State or insofar as the holding in respect of which the dividend is paid is effectively connected with a permanent establishment or a fixed base situated in the a to get other State , nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State. Article 11 interest 1-interest arising in a Contracting. The State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it «arise and according to the law of that State, but if the beneficial owner of the interest is a resident of the other Contracting State the tax so charged shall not exceeds 100 10 per cent of the gross amount of the interest. 3. Notwithstanding the provision of paragraph 2 of this article interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including local authorities and its political subdivisions, the Central Bank, the State Joint Stock Company "Latvian export credit" (Latvian eksportkredīt), an export Company Sloven (Slovenska izvozn a druzb), or interest derived on loans guaranteed by the "Latvian export credit" or the Sloven export Company shall be the main from tax in the first-mentioned State. 4. The term "interest" as used in this article means income from debt claims of every kind, whethers or not secured by mortgage and whethers or not carrying a right to participat in the debtor's profits, and in particular, income from government securities and income from bonds or debentur, including premium and prizes attaching to such securities, bonds or debentur. The term "interest" shall not include any income which is treated as a dividend under the provision of article 10. Penalty charges for late payment shall not be regarded as interest for the purpose of this article. 5. The provision of paragraphs 1, 2 and 3 of this article shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the debt claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this Convention. Article 12 to 1 to ROYALT Royalt arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may be taxed in royalt also in the Contracting State in which they «arise and according to the law of that State, but if the beneficial owner of the royalt to is a resident of the other Contracting State, the tax so charged shall not exceeds 100 10 per cent of the gross amount of such 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 or other means of image or sound reproduction for radio and television broadcasting, any patent, trade mark, design or model , plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 of this article shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, having regard to the use, right or information for which they are paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this Convention. Article 13 CAPITAL gains 1. Gains derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State or shares in a company the assets of which mainly of such property be consis may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services , including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft shall be only in the taxabl you state. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3 of this article, shall be the 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 dependent PERSONAL services 1-subject to the provision of articles 16, 18, 19 and 20, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be only in taxabl that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1 of this article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in the twelve month period commencing or any 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 directors ' fees directors ' fees and other similar payments derived by a resident or remuneration 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 of this article 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 political subdivisions or local authorities thereof. In such case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident. Article 18 PENSION subject to the provision of paragraph 2 of article 19, and other similar remuneration paid pension to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. Article 19 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be only in the taxabl you state. (b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be only in the taxabl you state. (b) However, such pension shall be) taxabl only in the other Contracting State if the individual is a resident of, and a national of, that State. 3. The provision of articles 15, 16, 17 and 18 shall apply to salar, and other similar remuneration, WAGs and their pension, in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof. Article 20 PROFESSOR AND RESEARCHER. An individual who visits a Contracting State generally for the purpose of teaching or carrying out research at a university, college or other recognised educational or scientific institution in that Contracting State and who is or was immediately before that visit a resident of the other Contracting State, shall be exempted from taxation in the first-mentioned Contracting State on remuneration for such teaching or research for a period not exceeding two years from the date of his first visit for that purpose. 2. The provision of paragraph 1 of this article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. Article 21 STUDENTS payments which a 1 student, an apprentice or a trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receive for the purpose of his maintenance, education or training shall not be taxed in that State , provided that such payments «arise from sources outside that State. 2. In respect of the payments not covered by paragraph 1 of this article, and remuneration for personal services rendered dependent during such education or training, a student, an apprentice or a trainee shall be entitled to the same relief, exemption or reduction in respect of taxes on income as are available to the residents of the Contracting State he is visiting. Article 22 OTHER income 1-items of income. of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Convention shall be only in the taxabl you state. 2. The provision of paragraph 1 of this article shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. Article 23 CAPITAL 1. Capital represented by immovabl property referred to in article 6, owned by a resident of a Contracting State and situated 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 and 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 24 methods FOR ELIMINATION OF double TAXATION double taxation shall be eliminated as follows: 1. In Slovenia: a) where a resident of Slovenia income or of deriv own capital which, in accordanc with the provision of this Convention, may be taxed in Latvia, Slovenia shall allow: (i) as a deduction in "from the tax on the income of that resident, an amount equal to the income tax paid in Latvia; (ii) as a deduction in "from the tax on the capital of that resident, an amount equal to the capital tax paid in Latvia. Such marbles in either case shall not, however, exceeds 100 that portions 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. (b)) where in accordanc with any provision of the Convention income derived or capital owned by a resident of Slovenia is main from tax in Slovenia, Slovenia 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. 2. In Latvia: a) where a resident of Latvia or of deriv income own capital which, in accordanc with this Convention, may be taxed in Slovenia, unless 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 Slovenia; (ii) as a deduction in "from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in Slovenia; Such marbles in either case shall not, however, that about 12 of the income tax or the 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 Slovenia. (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 Slovenia in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Slovenia 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 25 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, notwithstanding the provision of article 2, apply to taxes of every kind and description. Article 26 MUTUAL agreement procedure 1-where a person consider. that the actions of one or both of the Contracting States result or will result for him in taxation not in accordanc with the provision of this Convention, he may, irrespectiv of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or , if his case comes under paragraph 1 of article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordanc with the provision of the Convention. 2. The competent authority shall endeavour, if the objection to it appear to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordanc with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any difficult to doubt arising as it is or the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 4. The competent authorities of the Contracting States the may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. Article 27 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is not cessary for carrying out the provision of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of , or the determination of appeal in relations to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purpose. They may be published by the information in disclos court proceedings or in judicial decisions. 2. In no case shall the provision of of paragraph 1 of this article be construed so as to impost on a Contracting State the obligation: a to carry out administrative) measure the at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not) obtainabl is under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclos) any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). Article 28 members OF DIPLOMATIC missions AND CONSULAR posts Nothing in this Convention shall be affec the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provision of special agreements. Article 29 ENTRY into force 1. The Governments of the Contracting States shall notify each other when the constitutional requirements for the entry into force of this Convention have been complied with. 2. The Convention shall enter into force on the date of the later of the notifications referred to in paragraph 1 of this article and its provision shall have effect in both Contracting States: a in a) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the Convention enter into force; (b)) in respect of other taxes on income and taxes 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 Convention enter into force. Article 30 TERMINATION this Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year. In such event, the Convention shall cease to the have effect in both Contracting States: a in respect of taxes) withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (b)) in respect of other taxes on income and taxes 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 authorized, have signed the theret this Convention. Done in duplicate at Ljubljana this 19 days of April 2002, in the Latvian, Slovenian and English languages, all three texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Government of the Republic of Latvia For the Government of the Republic of Slovenia Maris Riekstins Darko Končan PROTOCOL at the signing of the Convention between the Government of the Republic of Latvia and the Government of the Republic of Slovenia for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on Capital (hereinafter referred to as "the Convention"), both sides have agreed upon the following provision which will form an integral part of the Convention: 1. In respect to article 4 (3) where a person other than an individual is a resident of both Contracting States and the competent authorities of the Contracting States the endeavour to determin it status by mutual agreement, they shall have regard to such factors as the place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. 2. In respect to article 6 and article 13 It is understood that all income and gains from the alienation of property referred to immovabl in article 6 and situated in a Contracting State may be taxed in accordanc with the provision of article 13. In witness whereof the undersigned, duly authorized, have signed the theret this Protocol. Done in duplicate at Ljubljana this 19 days of April 2002, in the Latvian, Slovenian and English languages, all three texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Government of the Republic of Latvia For the Government of the Republic of Slovenia Maris Riekstins Darko Končan