The Saeima has adopted and the President promulgated the following laws: For the Republic of Latvia and Romania 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. 25 March 2002 in Bucharest signed in the Republic of Latvia and Romania Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter the Convention) and its 25 March 2002 in Bucharest signed the 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 30 within the time and in order, and the Ministry of Foreign Affairs shall notify the newspaper "journal". The Parliament adopted the law of 20 June 2002. State v. President Vaira Vīķe-Freiberga in Riga on July 3, 2002 in the Republic of LATVIA and Romania to the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital of the Republic of Latvia and Romania on the basis of the desire to develop and strengthen economic relations, concluding the 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 on capital, irrespective of their method of collecting levies a Contracting State, the authorities or administrative territorial units. 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, the proceeds of disposal of earned income and capital appreciation. 3. The existing taxes to which this Convention applies, in particular, is: (a)): (i) corporate income tax;     (ii) the individual income tax;     (iii) the property tax;     (iv) the tax on immovable property; (hereinafter referred to as the Latvian tax); (b)) in Romania: (i) the individual income tax;     (ii) the profit tax;     (ii) salaries and other similar income tax;     (iv) agricultural activities income tax;     (v) the tax on dividends;     (vi) building tax;     (VII) land tax; (hereinafter tax in Romania). 4. this Convention shall apply also to any identical or substantially similar taxes which, supplementing or replacing the existing taxes will be introduced after the date of signature of this Convention. Of both national authorities are required to inform each other of any substantial amendments to this country in the relevant tax legislation.  Article 3 General definitions 1. If it is not apparent from the context, otherwise in this Convention: a the term "Contracting State)" and "the other Contracting State" depending on the context represents the Latvia or Romania; (b)) the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the legislation of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (c) the term "Romania") represents the Romanian State territory, including its territorial waters and air space over the territory and territorial waters, for which Romania exercises its sovereign rights, as well as those of the adjacent zone, the continental shelf and the exclusive economic zone, for which, in accordance with domestic legislation and international rules and principles of law, Romania shall exercise their sovereign rights and jurisdiction; (d) the term "person") denotes a physical person, the company and any other body of persons; e the term "company") represents any corporate person or any entity in the Association, 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" represents the company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; g) the term "international traffic" means any carriage by sea or air, 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 Latvia: the Ministry of finance or its authorised representative;     (ii) the Ministry of finance in Romania or its authorized representative; I) the concept of "citizen" represents: (i) in Latvia: any natural person who is a citizen of Latvia, and any legal person, partnership or association, which stems from the status of Latvia's legislation in force;     (ii) Romania: any natural person who is a citizen of Romania, and any legal person, any person, or any other entity status stems from the Romania legislation in force. 2. the application of this Convention at any time by a Contracting State any term will be used that is not defined here, only in the sense that if one is not apparent from the context in which it otherwise during the use of this legislation of a Contracting State in respect of 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 concept of explanations under other law of this State.   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 of the actual management, place of incorporation (registration) or any other similar criteria in nature. The concept also includes the Government of a Contracting State, its local authorities and administrative and territorial units. But this term does not include any person to whom this country is taxable only on their income from existing sources in that State or on capital situated in that State. 2. Where, in accordance with the provisions of paragraph 1 an individual is a resident of both Contracting States, its status will be determined in the following manner: (a)) this person will be treated as a resident only of the State in which they habitually resident; If you are habitually resident in two countries, this person will be considered only for residents of the State, with which it has closer personal and economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it does not have a permanent place of residence in one of the two countries, that person will be considered only for residents of the country where it is common 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 the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the Contracting State the competent authorities shall endeavour to resolve the matter by mutual agreement and determine the mode of application of this Convention to such person.   Article 5 permanent establishment 1. In this Convention, the term "permanent establishment" means a fixed place of business of which is wholly or partly carried on business. 2. The term "permanent establishment" includes: (a) the management of the company); b) branch; c) Office; (d) a factory;) e) workshop; and (f)) mine shaft, oil or gas extraction sites, quarries or any other place of extraction of natural resources. 3. Construction, Assembly, Assembly or installation project or a supervisory or related advisory transaction will be considered permanent representation only if this construction site, project or activity take longer than six months. 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 designed exclusively for the purchase of goods or products or information collection needs; e) permanent site designed exclusively for making enterprise well, any other arrangements or activities; f) permanent site designed exclusively for making this point a) to (e)) the activity referred to in any combination thereof, provided that the overall activity of the preparatory or ancillary nature is. 5. it will be considered that the Contracting State does not have permanent representation in the other Contracting State if the company after the closing of the exhibition or trade fair only sells and only owned the goods or products that are demonstrated in this trade fair or exhibition. 6. Notwithstanding paragraphs 1 and 2 of the regulations, if a person not referred to in paragraph 7, the independent status of the agent running the business and generally Contracting State used its powers to enter into contracts on behalf of this company, be deemed that this company has a permanent establishment in that State in respect of any the person's business activities, except where a permanent place of business used by this person making 4 or 5, paragraph, cannot be regarded as permanent representations in accordance with the provisions of paragraph 1. 7. 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. 8. the fact that the company is a resident of a Contracting State-controlled company, which is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking itself does not turn into one of those companies on the other company's permanent representation.  Article 6 Income from real property 1. income for the 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 '' will have the meaning it has in its legislation of a Contracting State in which the property is located. In any case, this concept will be used to refer to real estate property belonging to property, livestock and equipment used in agriculture and forestry; the rights covered by the provisions of general legislation on the ground attached to the 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 their use. For real estate will not be considered to be vessels and aircraft. 3. paragraph 1 of this article, the rules will be applied in relation to the income from immovable property directly, letting or use in any other way. 4. If the company's shares or other corporate rights give the holder the right to public use of the property, the income from the direct use, letting or use in any other way can be taxing in the Contracting State in which the immovable property is situated. 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 property that is 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 to the profit which is attributable to that permanent establishment. 2. in accordance with the provisions of paragraph 3, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit that this representation could benefit if the individual is clearly the company that performs the same or similar business activities under the same or similar conditions and works independently from this company. 3. in determining the profits of the permanent representation will be made permanent representation expense deduction from amounts taxable. These expenses may be representations of operational and general administrative expenses incurred by the country in which the permanent establishment or elsewhere. This provision must be applied in accordance with the Contracting State in which the permanent establishment is situated, legislative restrictions with regard to such deductions. 4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between its departments, paragraph 2 does not preclude the contracting country as usual to determine the taxable profit by this principle; However, this method of distribution must be used so that the results match the principles contained in this article. 5. On the permanent representation will not be applied the earnings just because it has purchased your business goods or articles. 6. the preceding paragraphs of this article apply to the permanent representation of the attributable profit of each year must be determined by the same method, except when there are sufficient grounds to act otherwise. 7. If the profit includes income type, which is discussed separately in other articles of this Convention, the provisions of this article shall not affect the other provisions of this article.  Article 8 of sea 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 where: 1 a) Contracting State the company 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's capital, and in any case these two companies in commercial or financial relations are created or established by the rules that are different from the rules, which will 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, where the taxable profit, in respect of which no 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 companies would have been as exist between two independent companies, the other countries have to make appropriate corrective tax size that is taxed in the other State of this profit. In determining this corrective, account must be taken of other provisions of this Convention and, if necessary, shall be held by the competent authorities of the Contracting States for consultations.  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 the real owner of the dividends is a resident of the other Contracting State, the tax shall not exceed 10 per cent of the gross amount of the dividends. 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, not claims, as well as income from other rights (including corporate law), which, in accordance with its national legislation, which the resident is a company that 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 be applied where the real owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment there, existing, or provide other State independent personal services from a permanent base located there, where the company that dividends, is the other State residents and where participation, which is paid out in dividends, is actually related to the permanent representation or permanent base. In this case, depending on the circumstances are applicable to article 7 or article 15. 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 duty of the dividends paid by the company, except when dividends are paid to a resident of that 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 country, nor to retained earnings in the company's retained earnings even When 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. 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, one where the recipient and the true owner is the Government of the other Contracting State, including its municipal or administrative territorial units, the central bank or any other this Government completely owned financial institutions as well as percentage that received the second State loans guaranteed by the Government, will not be taxed in the first country. 4. for the purposes of this article, the term "interest" means income from debt claims of any type, regardless of the security of a mortgage, especially income from government securities and income from bonds, promissory notes, including bonuses and awards for these securities, bonds or debentures. Interest received on payments made within that time will not be considered interest covered by this article. 5.2.1 of this article and paragraph 3 shall not be applied, if the interest owner will exercise, being 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 provide this second country independent personal services through a permanent base located there, and the claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances are applicable to article 7 or article 15. 6. interest will be deemed to arise in a Contracting State when the payer of the interest is a resident of that State. If, however, the person paying the interest, whether that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which incurred debt obligation, for which the interest is paid, 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, due to the special relationship between the payer and the interest percentage implemented owner or between both of them and a third person interest amount, relating 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. In this case, the remaining part of the payment is taxed in accordance with the national provisions, provided that you comply with the other provisions of this Convention.  12. Article 1 of the Commission fees incurred in the Contracting State and is paid to residents of the other Contracting State, may be taxing in that other country. 2. However, this fee can be taxing in accordance with national law of the Contracting State in which it arises. Where the Commission implements the owner is a resident of the other Contracting State, the tax shall not exceed 2 per cent of the total fee. 3. The term "commissions" in this article means payments received by a broker, agent or any other person who, in accordance with its national law, in which the Commission is seen as a broker or agent. 4. the following article 1 and 2 of the terms will not apply, if the true owner of the fee, being a resident of a Contracting State, carries on business in the other Contracting State, in which the Commission, using the existing permanent representation there, or in another country provides independent personal services through a permanent base located there, and if the activities for which the fee is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances are applicable to article 7 or article 15. 5. If the Commission fee payer is a resident of a Contracting State, it will be considered that the Commission come from this country. However, if the person who paid the fee, regardless of 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, is related to activities for which the fee is paid and the fees paid to (bear) permanent establishment or fixed base, will be considered that the fee incurred in the State in which the permanent establishment or fixed base. 6. If due to the special relationship between the payer of commissions and fees implemented owner or between both of them and a third person the amount of the fee that relates to activities for which it is paid, exceeds the amount of the fee 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 payment of the part exceeding this amount are taxed according to each Contracting State law provided that you comply with the other provisions of this Convention.  Article 13 royalties 1. Royalties arising in a Contracting State and is paid to residents of the other Contracting State, may be taxing in that other country. 2. However, such royalties may be taxing in accordance with national law of the Contracting State in which it arises. If the true owner of the royalties is a resident of the other Contracting State, the tax shall not exceed 10 per cent of the total royalties. 3. The term "royalties" in this article means payments of any kind received as a consideration for the use of any copyright or rights to use any copyright on literary, artistic or scientific work (including cinematograph films, and films or recordings of radio or television broadcasts, payments for transmission to consumers via satellite, cable, fibre optic cable or similar technology) to 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 it, or for information concerning industrial, commercial or scientific activity and experience. 4. the following article 1 and 2 of the terms will not be applied where the real owner of the royalties, being 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 in another country provides independent personal services through a permanent base located there, and if the rights or property of, subject to royalty payments, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances are applicable to article 7 or article 15. 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 due to the special relationship between the payer of royalties and royalties shall implement the owner or between both of them and some third-party image the amount relating to the rights of use or information 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 payment of the part exceeding this amount are taxed according to each Contracting State law provided that you comply with the other provisions of this Convention.  Article 14 capital gains 1. Capital gains or income for the resident of a Contracting State alienates a referred to in article 6, in the other Contracting State the existing real estate, or the shares of which are active mainly consists of the following property, can be taxing in that other country. 2. Capital gains earned on the property, which is an enterprise of a Contracting State in the other Contracting standing representative offices in the country to be used in business ownership, disposal or on property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which created the independent personal services, the disposal of assets, including capital gains 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 for the company of a Contracting State alienates the company used in international traffic, marine or air transport or disposal of the property that is associated with the sea or air vehicles, shall be taxable only in that State. 4. Capital gains arising on the disposition of any property that differs from the 1.2 and 3, referred to in paragraph 1 shall be taxable only in the Contracting State of which the resident is the seizure of property.  Article 15 independent personal services of a resident of a Contracting State 1 — natural persons income earned by providing professional services or other independent activities, will be taxed only in the country. However, such income may be taxed in the other Contracting State if: (a)) this person your actions, uses regular access to a permanent base in the other Contracting State but only to the extent that such income is attributable to this permanent base; (b) the person staying) in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any twelve month period commencing or ending in the taxation year, but may be taxed only on income earned in the other Contracting State actions. 2. The term "professional services" includes independent scientific, literary, artistic, educational or teaching activities as well as doctors, lawyers, engineers, architects, dentists and accountants of independent operation.  Article 16 dependent personal services 1.17, 19, 20, and the provisions of article 22. salaries, wages and other similar remuneration received by a resident of a Contracting State for paid 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 the provisions of paragraph 1, remuneration 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 that exceed 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) permanent establishment or fixed base which the employer has in the other State is used. 3. Notwithstanding the foregoing provisions of this article remuneration for work carried out by working on the enterprise of a Contracting State in international traffic, use of sea or air means of transport can be taxing in the country.  Article 17 Directors ' fees directors ' fees and other similar payments received by a resident of a Contracting State as a company that is a resident of the other Contracting State, the Board of directors or other similar institutions in the Member States, can be taxing in the other Contracting State.  Article 18 artists and athletes 1. articles 15 and 16 of the rules of income, the resident of a Contracting State as izpildītājmāksliniek, such as theatre, film, radio or television actor as well as a musician or an athlete for your 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 are paid not the artist or athlete but to another person, that income regardless of 7, 15 and 16 of article can be taxing the Contracting State to which the izpildītājmāksliniek or athletes. 3.1 and 2 of this article, the provisions will not apply to income earned on the action taken by a Contracting State or an athlete, an artist if they visit this country wholly or mainly support one or both of the Contracting States or of their local government, or administrative territorial units for public funds. In this case, the income will be taxed taxes only in the Contracting State of which the resident is the artist or athlete.  Article 19 pensions 1. According to article 20, paragraph 2 of the pension, annual fees and other similar remuneration for the previous paid employment received by a resident of a Contracting State will be subject to tax only in the country. 2. Notwithstanding the provisions of paragraph 1, pensions and other similar payments which are paid in accordance with national social security legislation will be subject to tax only in the country. 3. The term "annual fees" means a specified amount payable periodically to a natural person, the person's specified time limits life or a particular or determinable period of time in accordance with the obligation to make payments against previously received adequate and full consideration in money or money's worth of stuff.   Article 20 government service 1 a) salaries, wages and other similar remuneration, other than a pension, and a natural person the cost of Contracting State or of its local authorities or administrative territorial unit of that State, or local government unit services 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 for the purposes of providing the services. 2. (a) Any pension) that natural person the cost of Contracting State or of its local authorities or administrative territorial unit, or which it paid from that Contracting State or a local government, or the unit create funds for services provided by that person in that State, municipality or 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. Wages, salaries, other remuneration and pensions, similar to that you receive for services rendered in connection with a Contracting State or of its local authorities, or administrative territorial units, the business must apply to the 16, 17 and article 19.  Article 21 students and trainees payments which a residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State, a resident of and located in the first mentioned State solely for the purpose of study or placement period, will not be taxed in that State, provided that such payments arise outside that State.  Article 22 professors and researchers 1. income, on teaching or research work shall receive physical person entering Contracting State with a view to teach or engage in research at a University, college or other recognized that Contracting State educational or scientific institution and 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 that person for that purpose, first arrived in the Contracting State. 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 interest.  Article 23 other income 1. in previous articles of this Convention shall not featured resident of a Contracting State other income regardless of the sources of income, 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 recipient of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment there, existing or in that other State independent personal services from a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances are applicable to article 7 or article 15.  Article 24 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 sea and air vehicles that the company of a Contracting State in international traffic are used, as well as movable property belonging to the maritime and air transport, will be subject to tax only in that Contracting State. 4. All the other Contracting State, a resident of the capital items will be taxed only in the country.  Article 25 elimination of double taxation 1. In Latvia, double taxation will be avoided in the following manner: (a)) in case the resident of Latvia derives income or owns capital which, in accordance with the provisions of this Convention can be taxing in Romania, where one of the Republic of Latvia in internal legislation does 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 Romania;     (ii) reduce the capital residents a tax on that portion of the tax is equal to the capital tax paid in Romania. These reductions, however, shall in no case exceed the income tax or capital tax, part of which is calculated in Latvia before the application of this reduction depending on the circumstances, which is attributable to the income or the capital which can be taxing in Romania; (b)) (a) for the application of this section, if the company) — a resident of Latvia receives a dividend from a company resident in Romania and in-company Latvian resident owns at least 10 percent of shares with full voting rights, the tax paid in Romania to be included not only tax that taxed dividends, but also tax, which taxed the public profits from which dividends are paid, the part corresponding to these dividends. 2. In Romania, double taxation shall be avoided as follows: where a resident of Romania to generate income or owns capital which, in accordance with the provisions of this Convention can be taxing in Latvia, Romania should permit: (a) the resident's) reduce income tax for an amount equal to the income tax paid in Latvia; (b) the resident's capital) to reduce tax on an amount equal to the capital tax paid in Latvia. These reductions must not, however, exceed the income tax or capital tax, part of what is calculated before this fall, depending on the circumstances, which is attributable to the income or the capital which can be taxing in Latvia.  Article 26 discrimination prevent 1. nationals of a Contracting State in the other Contracting State shall not be subject to taxation or any requirements connected therewith which differs from taxation or the related requirements which are or may be exposed to the other citizens of the country in the same circumstances, or which is more burdensome, especially with regard 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. a Contracting State a permanent establishment, the representative which it uses 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 or reductions in respect of taxation, which this country give its residents, in the light of their civil status or family responsibilities. 3. Except where the applicable paragraph 1 of article 9, paragraph 7 of article 11, paragraph 6 of article 12 or paragraph 6 of article 13 of the regulations, interest, fees, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident, in determining the taxable profit of the company, must be deducted from the profits subject to the same provisions 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 subject to the same provisions as if they would apply to the first residents of that State. 4. the Contracting State whose capital is wholly or partly belongs to one or more of the other Contracting State residents or that these residents are directly or indirectly controlled by, the first in that country may not be subject to taxation or any requirements connected therewith which differ from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises, or which is more burdensome. 5. Notwithstanding the provisions of article 2, the provisions of this article apply to each type and name.  Article 27 mutual conciliation procedure 1. If a person believes that one or both of the Contracting States party to the cause or may cause the person's 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, submit your question for consideration by the competent authorities of the country of which that person is resident, or, if the matter relates to article 26, paragraph 1 of the Member State the competent authorities of which are this person. The question to be submitted for review within three years from the first notification of the action that caused the taxation not in accordance with the provisions of this Convention. 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. Each such agreement is reached must be met regardless of the contracting domestic legislation established time limits. 3. the national competent authorities should seek mutual coordination towards resolving any difficulties or eliminate doubts which may arise in the interpretation or application of this Convention. They may also consult to resolve double taxation cases which are not provided for in this Convention. 4. The competent authorities of the Contracting States may communicate directly with one another in order to reach agreement on the question referred to in the previous paragraphs. If it seems appropriate to reach agreement is verbal exchanges, such exchanges can happen by creating a Commission, composed of the competent authorities of the Contracting States.  Article 28 exchange of information 1. National authorities should exchange information necessary for the carrying out of the provisions of this Convention or of the domestic legislation of the Contracting States of acts on taxes to which this Convention applies, the requirements, to the extent that these laws are 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 taxes to which this Convention applies, in the calculation of the collection, the application of coercive measures, the prosecution of a legal liability or appeals to these taxes. Such persons or authorities, this information must be used only for the purposes mentioned above. They may disclose the information in public hearings or in judgements. 2. the provisions of paragraph 1 may not be explained so that they bind the Contracting State the obligation: a to carry out administrative measures), which does not comply with one or other of the contracting national legislation and administrative practice; (b)) to provide information that is not available under one or the other national legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to the public interest (ordre public).  Article 29 diplomatic and consular personnel, nothing in this Convention shall not affect the diplomatic missions or consular posts personnel fiscal privileges which the then applicable under general international law provisions or special agreements.  Article 30 entry into force this Convention shall enter into force on the date of the last notification that indicates that the State has met the constitutional requirements for the Convention to enter into force. The application of the provisions of the Convention will be launched: a): (i) in respect of taxes withheld at the time the costs — starting with the income for the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force;     (ii) in respect of other taxes on income and capital — from taxes payable in any tax year that begins on the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force; (b)) in Romania: (i) in respect of taxes withheld at the time the costs — starting with the income for the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force;     (ii) in the case of other profits, income and capital taxes — starting with the taxes to be paid in any taxation year that begins on the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force.  Article 31 termination this Convention shall remain valid as long as the contracting party terminates its activities. 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 will end: a): (i) in respect of taxes withheld at the time the costs — starting with the income for the first day of January or after the first day of January in the calendar year following the year in which the notes in question;     (ii) in respect of other taxes on income and capital — from taxes payable in any tax year that begins on the first day of January or after the first day of January in the calendar year following the year in which the notes in question; (b)) in Romania: (i) in respect of taxes withheld at the time the costs — starting with the income for the first day of January or after the first day of January in the calendar year following the year in which the notes in question;     (ii) in the case of other profits, income and capital taxes — starting with the taxes to be paid in any taxation year that begins on the first day of January or after the first day of January in the calendar year following the year in which the relevant note. This, the undersigned, being duly authorised, have signed this Convention. The Convention drawn up in Bucharest on 25 March 2002, in two copies, each of them Latvian, Romanian and English. Each of these texts being equally authentic. Different case is decisive for the interpretation of the text in English.  

On behalf of the Republic of Latvia Andris Berzins on behalf of Romania Adrian Saying signing the Protocol of the Republic of Latvia and Romania 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 parties have agreed upon the following provisions, which are an integral part of the Convention. (I). The Contracting States agree that, with respect to the operation of the ice area is applicable to the following article: "1. The provisions of this article must be applied irrespective of the Convention article 4 to 22. 2. In this article the term "offshore area" means the contracting country shelf area perform the action associated with this national sea and subsoils and keep the existing natural resources exploration and exploitation. 3. persons — residents of a Contracting State activity that is performed in the other Contracting State, ice area, in accordance with paragraph 4 of this article, the rules will be treated as a business that is carried on in the other Contracting State through a permanent establishment there existing or permanent base. 4. paragraph 3 of this article shall not be applied, if the action is carried out in the area of the shelf during the period or periods not exceeding in the aggregate 30 days in any 12-month period that begins or ends in the tax year concerned. The application of this paragraph: (a) the shelf zone), a person is associated with another person, be deemed to be the person to take action, if this action is essentially the same as its first performed by that person, other than a first-person action that is carried out simultaneously with the other activities of the person; (b)) a person shall be deemed to be associated with another person if one of them directly or indirectly controls the other or a third person or third party directly or indirectly controls both parties. 5. the wages, earnings, and other similar remuneration received by a resident of a Contracting State for gainful work associated with the activity of the other contracting country of the shelf area, can be taxing in that other State to the extent that work has been done in this country to the other shelf area. However, such remuneration will be taxed only in the first country, where paid work has been made in favour of the employer who is not a resident of the other State, and it is carried out during a period or periods not exceeding in the aggregate 30 days in any twelve-month period that begins or ends in the tax year concerned. 6. income which a resident of a Contracting State alienates a benefit: (a)) or use the right to study; or (b)) property, which hosted the second Contracting State and used in connection with the second shelf of this state of the activities in the area; or (c)), which shares your values or values most directly or indirectly derived from the above rights or property, or the rights and property of these together, this can be taxing in the other country. In this article, the term "exploration or exploitation rights" means the right to property, which can be generated by activities in the other Contracting State, or a shelf right to ownership or profit participation that may result in this property. " II. In respect of article 26 it is understood that the stateless persons who are residents of a Contracting State, any of the Contracting States shall not be subject to taxation or any requirements connected therewith which differs from taxation or the related requirements which are or may be exposed to nationals in the same circumstances, or which is more burdensome, especially with regard to residence. This, the undersigned, being duly authorised, have signed this Protocol. Protocol, drawn up in Bucharest on 25 March 2002, in two copies, each of them Latvian, Romanian and English. Each of these texts being equally authentic. Different case is decisive for the interpretation of the text in English.

On behalf of the Republic of Latvia Andris Berzins on behalf of Romania Adrian Saying the CONVENTION BETWEEN the REPUBLIC OF Latvia AND Romania FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income AND ON CAPITAL the Republic of Latvia and Romania, promote and strengthen it (menu rngton Line4) the economic relations by concluding a Convention 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 2 taxes 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 local authorities or its administrative territorial units, 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 with in particular: (a)) in the case of Latvia: (i) the enterprise income tax (income tax of enterprises); (ii) the personal income tax (will tax revenue); (iii) the property tax (property tax); (iv) the immovabl property tax (tax on immovable property); (hereinafter referred to as "Latvian tax"); (b)) in the case of Romania: (i) the tax on income derived by individual; (ii) the tax on profit; (iii) the tax on salar and others to similar remuneration; (iv) the tax on agricultural income; (v) the tax on dividends; (vi) the tax on the building; (VII) the tax on land; (hereinafter referred to as "Romanian 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 substantial changes to each which have been made in their taxation laws of respectiv. Article 3 GENERAL DEFINITION 1. For the purpose of this Convention, unless the context otherwise requires: a the term "a) Contracting State" and "the other Contracting State" mean Latvia or Romania, as the context requires; (b)) the term "United States" means the Republic of Latvia and, when used in the sense of location, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the law of Latvia and in accordanc with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub soil and their-natural resources; (c)), the term "Romania" means the State territory of Romania, including its territorial sea and air space over the territory and the territorial sea over which Romania exercises sovereignty, as well as the of the area and the contiguo a continental shelf and the exclusive economic zone over which Romania exercises, in accordanc with its legislation and with the rules and principles of international law , sovereign rights and jurisdiction; (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 the case of Latvia, the Ministry of finance or its authorised representative; (ii) in the case of Romania, the Ministry of finance or its authorised representative; (I) the term "national") means: (i) in the case of Latvia any individual possessing the nationality of a legal person, its affiliates and any partnership and association deriving its status as such from the law in force in Latvia; (ii) in the case of Romania any individual possessing the citizenship of Romania and any legal person, a body of persons and any other entity deriving its status as such from the laws in force in Romania. 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 which 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 local authority or administrative-territorial unit thereof. This term, however, does not include any person who is liabl to tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provision of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be) a resident only of the State in which he has a permanent home available to him; If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (Centre of vital interests); (b)) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; c if he has an habitual) abode in both States or in ither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if he is a national) of both States or of ither of them not, the competent authorities of the Contracting States shall settle the the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to the settle the question by their mutual agreement and determin the mode of application of the Convention to such person. 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 construction, assembly or installation project or a supervisory activity connected therewith or consultancy constitut a permanent establishment only if such site, project or activity lasts for a period of more than six months. 4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it sells goods or merchandise belonging to the enterprise displayed in the frame of a temporary trade fair or exhibition at the closing of the said fair or exhibition. 6. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraphs 4 and 5, if exercised through a fixed which place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it care to on business in that 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. 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other. Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of general law respecting landed property apply, usufruc of immovabl property and rights to variable or fixed payments as considerations for the working of, or the right to work, mineral deposits, sources and other natural resources. Ships and aircraft shall not be regarded as immovabl property. 3. The provision of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovabl property. 4. Where the ownership of shares or other corporate rights in a company the owner of entitl such shares or corporate rights to the enjoymen of immovabl property held by the company, the income from the direct use, letting, or use in any other form of such right may be taxed to the enjoymen in the Contracting State in which the immovabl property is situated. 5. The provision of paragraphs 1, 3 and 4 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as a deduction in "of which the expense incurred for the purpose of the permanent establishment, including Executive and general administrative expense so incurred, whethers of in the State in which the permanent establishment is situated or elsewher. This provision shall apply subject to the limitations under the domestic law of the Contracting State in which the permanent establishment is situated. 4. Insofar as it has been customary in a Contracting State to determin the profits to be attributed to a permanent establishment on the basis of an apportionmen of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclud that Contracting State from determining the profits to be taxed by such an apportionmen as may be customary; the method of apportionmen, however, the adopted shall be such that the result shall be in accordanc with the principles led in this article. 5. From the profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which the deal with separately in other articles of this Convention, then the provision of those articles shall not be affected by the provision of this article. Article 8 SHIPPING AND AIR transport 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxabl only in that State. 2. The provision of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Article 9 ASSOCIATED enterprises 1. Where (a) an enterprise of a Contracting) State of directly or indirectly participat in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons directly or indirectly the participat in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State , and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State — and taxes accordingly — profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises , then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provision of this Convention and the competent authorities of the Contracting States shall if the cessary not consult each other. Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceeds 100 10 per cent of the gross amount of the dividends. This paragraph shall not be affec the taxation of the company in respect of the profits out of which the dividend is paid with. 3. The term "dividends" as used in this article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other rights (including corporate rights) which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 15, 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, interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including its local authorities or administrative-territorial units, the Central Bank or any financial institution wholly owned by that Government, or interest derived on loans guaranteed by that Government shall be main from tax in the first-mentioned State. 4. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage, and in particular, income from government securities and income from bonds or debentur, including premium and prizes attaching to such securities, bonds or debentur. Penalty charges for late payment shall not be regarded as interest for the purpose of this article. 5. The provision of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 15, 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 COMMISSION 1 Commission 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 commission 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 commission is a resident of the other Contracting State, the tax so charged shall not exceeds 100 2 per cent of the gross amount of the commission. 3. The term "commission" as used in this article means a payment made to a broker, a general commission agent or any other person considered it to be a broker or agent by the taxation law of the Contracting State in which such payment «arise. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the commission, being a resident of a Contracting State, carr to one business in the other Contracting State in which the commission «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the activities in respect of which the commission is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 15, as the case may be, shall apply. 5. the Commission shall be deemed it «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the commission, 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 activities for which the payment is made, and such commission was incurred is borne by such permanent establishment or fixed base, then such commission shall be deemed it «arise in the Contracting 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 commission, having regard to the activities 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 13 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 the royalt. 3. The term "royalt" as used in this article means payments of any kind received as a considerations for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films or tapes for radio or television broad-casting, the transmission to the public by satellite, cable, optic fibre or similar technology) any patent , trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, any industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalt paid is effectively connected with such permanent establishment or with fixed base. In such case the provision of article 7 or article 15, 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 14 CAPITAL gains 1. Gains or income derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State 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 from the alienation of ships or aircraft operated in international traffic by that enterprise 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, shall be only in the taxabl Contracting State of which the alienator is a resident. Article 15 independent PERSONAL services 1-income derived by an individual. who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be only in the taxabl Contracting State a. But such income may be taxed also in the other Contracting State: a if he has a fixed) base regularly available to him in the other Contracting State for the purpose of performing his activities; but only so much of the income as is attributabl to that fixed base; (b) if his stay) in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in-the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Article 16 dependent PERSONAL services 1-subject to the provision of articles 17, 19, 20, and 22, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate 183 days in the in any twelve month period commencing or ending in the fiscal year concerned , and b the remuneration is paid by), or on behalf of, an employer who is not a resident of the other State, and c the remuneration is not) borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provision of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State. Article 17 directors ' fees directors ' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. Article 18 Artistes AND SPORTSMEN 1. Notwithstanding the provision of articles 15 and 16, 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, 15 and 16, be taxed in the Contracting State in which the activities of the entertainer or sportsman's are exercised. 3. The provision of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsman's if the visit to that State is wholly or mainly supported by public funds of one or both of the Contracting States or of their local authorities or administrative-territorial units. In such case, the income shall be taxabl only in the Contracting State of which the entertainer or sportsman's is a resident. Article 19 PENSION 1. Subject to the provision of paragraph 2 of article 20, pension, and other similar remuneration annuit paid to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. 2. Notwithstanding the provision of paragraph 1 and others of similar pension payments made under the social security legislation of a Contracting State shall be only in the taxabl you state. 3. The term "annuity" means a stated sum payable to an individual periodically at stated times during his life or during a specified period of time or ascertainabl under a commitment with an obligation to make the payments in return for adequat and full considerations in money or money's worth. Article 20 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or a local authority or an administrative-territorial unit thereof to an individual in respect of services rendered to that State or authority or unit shall be only in the taxabl you state. (b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State or a local authority or an administrative-territorial unit thereof to an individual in respect of services rendered to that State or authority or unit 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 16, 17 and 19 shall apply to salar, and other similar remuneration, wage and pension, in respect of services rendered in connection with a business carried on by a Contracting State or a local authority or an administrative-territorial unit thereof. Article 21 students AND TRAINE-payments which a student, an apprentice or a trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receive for the purpose of his maintenance, education or training shall not be taxed in that State , provided that such payments «arise from sources outside that State. Article 22 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 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 23 OTHER income 1-items of income. of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Convention shall be only in the taxabl you state. 2. The provision of paragraph 1 shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the 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 15, as the case may be, shall apply. Article 24 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 25 ELIMINATION OF double TAXATION 1. In the case of corporation taxation shall be eliminated as doubles follows: a) where a resident of Latvia or of deriv income own capital which, in accordanc with this Convention, may be taxed in Romania, unless a more favourabl treatment is provided in its domestic law, Latvia shall allow: (i) as a deduction in "from the tax on the income of that resident , an amount equal to the income tax paid thereon in Romania; (ii) as a deduction in "from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in Romania. Such marbles in either case shall not, however, that about 12 of the income tax or capital tax in Latvia, as computed before the deduction in "is given, which is attributabl, as the case may be, to the income or the capital which may be taxed in Romania. (b)) For the purpose of subparagraph (a)) of this paragraph, where a company that is a resident of Latvia receive a dividend from a company that is a resident of Romania in which it will own at least 10 per cent of its shares having full voting rights, the tax paid in Romania shall include not only the tax paid on the dividend , but also the appropriate portions of the tax paid on the underlying profits of the company out of which the dividend was paid. 2. In the case of double taxation shall be Romania eliminated as follows: where a resident of Romania or of deriv income own capital which, in accordanc with the provision of this Convention may be taxed in Latvia, Romania shall allow: a as a deduction in ") from the tax on the income of that resident, an amount equal to the income tax paid in Latvia; (b) as from the marbles) 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, that about 12 of the income tax or capital tax, as computed before the deduction in "is given, which is attributabl, as the case may be, to the income or the capital which may be taxed in the United Kingdom. Article 26 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. 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. 3. Except where the provision of paragraph 1 of article 9, paragraph 7 of article 11, paragraph 6 of article 12 or paragraph 6 of article 13, apply, interest, commission, 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 under the same-deductibl condition 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. 4. 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. 5. The provision of this article shall, notwithstanding the provision of article 2, apply to taxes of every kind and description. Article 27 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 26, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordanc with the provision of the Convention. 2. The competent authority shall endeavour, if the objection to it appear to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordanc with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any doubt arising as to the difficult or is it the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 4. The competent authorities of the Contracting States the may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisabl in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting to States. Article 28 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is not cessary for carrying out the provision of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of , or the determination of appeal in relations to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purpose. They may be published by the information in disclos court proceedings or in judicial decisions. 2. In no case shall the provision of of paragraph 1 be construed so as to impost on a Contracting State the obligation: a to carry out administrative) measure the at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not) obtainabl is under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclos) any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). Article 29 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 30 ENTRY into force, the Convention shall enter into the force on the date of the later of the notifications indicating that the constitutional requirements for the entry into force of this Convention in each Contracting State have been complied with. The provision of the Convention shall have effect: (a)) in the case of Latvia: (i) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the Convention enter into force; (ii) in respect of other taxes on income 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; (b)) in the case of Romania: (i) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the Convention enter into force; (ii) in respect of other taxes on income and profit, on capital, for taxes chargeabl for any tax year beginning on or after the first day of January in the calendar year next following the year in which the Convention enter into force. Article 31 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 the effect. (a)) in the case of Latvia: (i) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (ii) in respect of other taxes on income 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. (b)) in the case of Romania: (i) in respect of taxes withheld at source on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (ii) in respect of other taxes on profits, income and on capital, for taxes chargeabl for any tax year beginning on or after the first day of January in the calendar year next following the year in which the notice has been given. In witness whereof, the undersigned, being duly authorised the theret, have signed this Convention. Done in Bucharest on 25 of March 2002, in two original versions, in the Latvian, Romanian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Republic of Latvia For Romania Andris Bērziņš Adrian Saying PROTOCOL At the signing of the Convention between the Republic of Latvia and Romania 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"), the undersigned have agreed upon the following provision, which shall form an integral part of the Convention : I. The Contracting States agree that in relations to offshore activities the provision of the following article shall apply: 1. The provision of this article shall apply notwithstanding the provision of Article 4 of the 22 of this Convention. 2. For the purpose of this article, the term "offshore activities" means 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. 3. A person who is a resident of a Contracting State and carr to on offshore activities in the other Contracting State shall, subject to paragraph 4, be deemed to be carrying on business in that other State through a permanent establishment situated therein or a fixed base. 4. The provision of paragraph 3 shall not apply where the offshore activities are carried on for a period or periods not exceeding in the aggregate 30 days within any twelve month period. For the purpose of this paragraph: a activities carried on offshore) by a person who is associated with another person shall be deemed to be carried on by the other person if the activities in question are substantially the same as those carried on by the first-mentioned person, except to the exten to that those activities are carried on at the same time as its own activities; (b) a person shall be deemed) to be associated with another person if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or third persons. 5. Salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment connected with offshore activities in the other Contracting State may, to the the exten that the duties are performed offshore in that other State, be taxed in that other State. However, such remuneration shall be taxabl only in the first-mentioned State if the employment is carried on for an employer who is not a resident of the other State for a period or periods and not exceeding in the aggregate 30 days in any twelve month period. 6. Gains derived by a resident of a Contracting State from the alienation of: (a) exploration or exploitation rights;) or (b)) property situated in the other Contracting State which is used in connection with the offshore activities carried on in that other State; or c shares deriving their value) or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together; may be taxed in that other State. In this paragraph the term "exploration or exploitation rights" means rights to assets to be produced by offshore activities carried on in the other Contracting State, or their interests in or to the benefit of such assets. " II. With reference to article 26 It is understood that the 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. In witness whereof, the undersigned, being duly authorised the theret, have signed this Protocol. Done in Bucharest on 25 of March 2002, in two original versions, in the Latvian, Romanian and English languages, all texts being equally authentic. In the case of the divergenc of interpretation the English text shall prevails.

For the Republic of Latvia Andris Berzins For Romania Adrian is Saying