The Government Of The Republic Of Latvia And The Qatari Government Agreement On The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income

Original Language Title: Par Latvijas Republikas valdības un Kataras Valsts valdības līgumu par nodokļu dubultās uzlikšanas un nodokļu nemaksāšanas novēršanu attiecībā uz ienākuma nodokļiem

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The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Qatari government agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes article 1. 2014 September 26 in New York signed by the Government of the Republic of Latvia and the Qatari government an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the Treaty) this law is adopted and approved. 2. article. Contractual commitments coordinated by the Ministry of finance. 3. article. The agreement shall enter into force for the period specified in article 29 and in order, and the Ministry of Foreign Affairs shall notify the official Edition of the "journal". 4. article. The law shall enter into force on the day following its promulgation. To put the contract in law Latvian and English. The Parliament adopted the law in 2014 11 December. The President a. Smith in Riga 2014 on December 17, the Government of the Republic of LATVIA and the QATARI Government an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income the Government of the Republic of Latvia and the Government of the State of Qatar, accepting his willingness to conclude an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows: article 1 persons covered this AGREEMENT shall apply to persons Contract that is one or both of the Contracting States residents. Article 2 taxes covered 1. CONTRACT this contract applies to income taxes imposed by the Contracting State or of its political or administrative units of local government, regardless of the method of collecting the tax. 2. income taxes deemed all taxes imposed on total income or on the part of income, including taxes on the capital gains of the movable or immovable property seizures. 3. The existing taxes to which the agreement relates, in particular: (a) in the case of the Republic of Latvia): (i) the corporate income tax; (ii) the individual income tax; (hereinafter referred to as "Latvian tax"); and (b) in the case of State of Qatar): (i) the income tax; (hereinafter referred to as "Qatari duties"). 4. the agreement shall also apply to any identical or substantially similar taxes which, supplementing or replacing the existing taxes are introduced after the date of signature of the Treaty. The competent authorities of the Contracting States inform each other of any substantial amendments made to the national tax legislation. Article 3 General definitions 1. If the context does not otherwise specified, then this risk‐adjusted Agreement): (a) the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the laws of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (b)), the term ' Qatar ' means the State of Qatar, and used in a geographical sense, it represents the Qatari State's land territory, internal waters, territorial sea, including the seabed and subsoil of land, air space above them, the exclusive economic zone and the continental shelf, where the Qatari government in accordance with international law and the Qatari national regulations implementing its sovereign rights and jurisdiction; (c) the terms "a Contracting State)" and "the other Contracting State" mean, depending on context or Qatar Latvia; (d)) the term "person" means a natural person, company, and any other Association of persons; e the term "company") means any association or any corporate entity for taxation purposes is considered a corporate Association; (f) the terms ") of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; (g)) the term "international traffic" means any transport by a ship or aircraft by an enterprise of a Contracting State, except when the ship or aircraft is moving only 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; and (ii) in the case of Qatar, the Ministry of finance or its authorised representative; I) the term "national", in relation to a Contracting State means: (i) any natural person who has the nationality of a Contracting State; (ii) any legal person, partnership or association, whose status as a result of these Contracting in force in national legislation. 2. a Contracting State at any time during the application of this agreement, all terms not defined therein, have the meanings to them at the time, the country's laws and regulations relating to taxes covered by the agreement, unless the context is otherwise, and the risk‐adjusted State the relevant tax legislation meaning prevails over other laws of this state the intended meaning. Article 4 resident 1. In this agreement, the term "resident of a Contracting State" means: (a) in the case of Latvia) any person who, under the laws of Latvia impose taxes based on their place of residence, residence, location management, the creation of the site or any other substantially similar criteria, and also includes the Republic of Latvia and any of its local or incorporated companies. However, this term does not include those individuals in Latvia, the taxes are imposed only in respect of their income from earnings in Latvia. (b) in the case of Qatar) any natural person who has his habitual residence, vital interests or its usual Centre home in Qatar and society established in Qatar. The term also includes the Qatari State and any of its political and administrative units, local authorities or incorporated companies. 2. Where, in accordance with the provisions of part 1 an individual is a resident of both Contracting States, its status would be as follows: (a) the person is considered to be) only for residents of the country in which they are habitually resident; If you are habitually resident in two countries, this person shall be deemed to be a resident only of the State, with which it has closer personal and economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it is not a permanent residence in one of the two countries, this person is considered a resident of the country only, which is its usual home; c) if that person normally home in both countries or is not one of them, it is considered to be the only resident in the country, which is a national of that person; (d) if appropriate) above (a), (b) and (c)))) as defined in points an individual's residence status is not possible, the competent authorities of the Contracting States resolved the matter by mutual agreement. 3. Where, in accordance with the provisions of part 1 a person other than an individual is a resident of both Contracting States, the competent authorities must seek to resolve the matter by mutual agreement. Article 5 permanent establishment 1. In this agreement, the term "permanent establishment" means a fixed place of business of the company, which is wholly or partly carried on business. 2. The term "permanent establishment" includes mainly: (a)) control location; b) branch; c) Office; (d) a factory;) e) workshop; f) premises used as a sales outlet; g) farm or plantation; and (h)) mine shaft, oil or gas extraction sites, quarries or any other natural resource exploration, extraction or exploitation of the site. 3. The term "permanent establishment" also includes: a a building site, construction), Assembly or installation project, or with any of these works and projects related to the monitoring of surveillance activities, but only if such works, projects or activities are carried out for a period or periods exceeding in total 6 (six) months in any 12 month period (twelve); and (b)) services, including advisory services, by company, employing the company's employees or other personnel, the company attracted for this purpose, but only if this type of activity (for the same or related project) are made in a Contracting State for a period or periods exceeding in total 6 (six) months in any 12 month period (twelve). 4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall not include: (a) the use of buildings and equipment) only and exclusively the goods belonging to, or for the storage of the products demonstrated or supplies; (b)) or of the goods belonging to the product items that are intended solely for storage, demonstration or delivery; (c)) or of the goods belonging to the inventory of products intended exclusively for processing in the other company. (d) the specific site) designed exclusively for the purchase of goods or products to your company's needs or the collection of information for the company's needs; (e)) site designed exclusively for making your business any other preparatory or ancillary activities; f) specific action site intended solely to deal with (a) to (e))) the following, in any combination thereof, if the combination of the action are generally preparatory or auxiliary character. 5. Notwithstanding the first subparagraph and (2) If a person who is not referred to in part 6 status of independent agent, running your business, and it has empowered the State to enter into contracts on behalf of the company, and it constantly uses this power, then in all activities carried out by such person for your business, it is considered that the company has a permanent establishment in the country concerned, unless such person has carried out only part 4 actions foreseen in the that perform certain actions in place, the place of action under the said part is not considered permanent representation. 6. It is considered that the company does not have permanent representation in the Contracting State where the undertaking is established in that country, using only the broker, agent or any other agent of an independent status, provided that such persons perform their normal business activities. However, when the activities of such an agent is completely or almost completely in favour of the company is carried out and that the company and agent in commercial or financial relations are created or established by the rules that are different from the rules, which will be in force between independent companies, he is not considered an independent agent status in this part in that sense. 7. The fact that the company-a resident of a Contracting State, controlled by the society, which is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking in itself does not mean that any of these companies is the second permanent representation of society. Article 6 INCOME from real property 1. income which a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State taxes. 2. The term "immovable property" shall have the meaning which it has its laws and regulations of a Contracting State in which the property concerned is located. In any case, this term covers property which belongs to real estate property including livestock and equipment used in agriculture and forestry, rights to which the land property law general rules and any option or similar right in respect of immovable property, real property and rights to variable or fixed payments as consideration for the mineral deposits, natural ore and other natural resources, or the right to use them. Vessels and aircraft are not considered real estate. 3. the provisions of part 1 apply to the income from immovable property directly, letting or use in any other way, as well as income from the alienation of immovable property. 4. If the company's shares or other corporate rights ownership gives the shares or corporate rights to the owner of the rights to the company's holding of real property, the income from the direct use, letting or use in any other manner may impose taxes in the Contracting State in which the immovable property is situated. 5.1, 3, and part 4 rules apply also in relation to income from the company's real estate, as well as income from real property used for independent personal services. Article 7 business profits 1. Contracting State company profits are taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment there. If the enterprise carries on business in that way, the company's profits may impose taxes in the other country, but only to the profit, which can be attributed to the permanent establishment. 2. in accordance with the provisions of part 3, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit margins, as it would if it had been separated and independent company that performs the same or similar business activities under the same or similar conditions and independently carry out transactions with the company that it is a permanent establishment. 3. in determining the profits of a permanent representation in that Contracting State, are allowed to deduct the expenses incurred for the purposes of the standing representative offices located in the country or elsewhere, including operational and general administrative expenses, which are allowed under the Contracting State in which the Permanent Mission, national legislation. 4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between its divisions, part 2 does not prohibit Contracting State as usual after this principle, determine the profit for tax purposes; However, the method of distribution must be such that the result matches the principles contained in this article. 5. On the permanent representation of the profits not only because it has purchased the goods or products for the company, which is the permanent representation. 6. for the purposes of applying the provisions of the preceding paragraph, the profits attributed to the permanent establishment shall be determined each year by the same method, except if there is sufficient reason to do otherwise. 7. If the profit is included in the other articles of this agreement are considered separate income type, this article shall not affect the other provisions of this article. Article 8 shipping and air TRANSPORT 1. Contracting State company profits of ships or aircraft in international traffic, the use of taxable only in that State. 2. The application of this article the company profit of ships or aircraft in international traffic shall include the use of: (a)) profit from ships or aircraft leasing, hiring them without crew and supply; and (b)) profit from containers (including trailers and related equipment for the transport of containers) use, maintenance or rental of goods or products; If such lease or such use, maintenance or rental occurs in addition to the company's ships or aircraft for use in international traffic. 3. the provisions of part 1 shall also apply to profits from the participation in a pool, joint business or international traffic transport agency. Article 9 ASSOCIATED enterprises 1. If: (a) the Contracting State) directly or indirectly participate in the company of the other Contracting State, in the controls or owns part of the company's capital; or (b)) the same persons directly or indirectly participating in the enterprise of a Contracting State in the other Contracting State and enterprise management, controls or owns part of the company's capital; and in any of these cases, these two companies in commercial or financial relations are created or established by the rules, which differ from those which would be in force between the two independent enterprises, then any profits which would, but for one of the companies affected by the above provisions did not have, can be included in the company's profits, and it may be appropriate to impose taxes. 2. where a Contracting State includes in the profits of an enterprise of that State and taxes accordingly profits on it, in respect of which no other country in the other Contracting State, the company has been taxed, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, the other country take appropriate adjustment for the size of the tax What are the gains of the other State, if it agrees with the adjustments, what is made in the first country. In determining this adjustment, take into consideration other provisions of this agreement and, if necessary, the competent authorities of the Contracting States for consultations. Article 10 dividends 1. Dividends company-a resident of a Contracting State, the cost of the other Contracting State, a resident may be taxed in that other State taxes. 2. However, such dividends may also impose taxes under the national laws of the Contracting State of which the resident is a company that pays dividends, but if this the real beneficiary of the dividends is a resident of the other Contracting State, the tax shall not exceed: (a)) 0 (zero) percent of the total amount of dividends, if the real beneficiary of the dividends is a company (other than a partnership); (b)) 5 (five) percent of the total amount of dividends in all other cases. This part shall not affect the taxation of company profits from which dividends. 3. Regardless of the part 2 (b)) States, part 1 in dividends taxable only in the Contracting State of which the resident is the true beneficiary where: (a)) the true beneficiary is a Contracting State, a political or administrative unit of local government, incorporated companies or the central bank; (b) in the case of Latvia) the true beneficiary organizations are the following: (i) the Latvian guarantee agency; (ii) any other institution, for which in the course of time mutually agreed by the competent authorities of the Contracting States; (c) in the case of Qatar, real) beneficiary is the following, to the extent its wholly owned Qatar: (i) the Qatari investment authority; (ii) the Qatari holdings; (iii) Pension Fund of Qatar; (iv) Qatar Development Bank; and (v) any other institution, for which in the course of time mutually agreed by the competent authorities of the Contracting States. 4. The term "dividends" in this article means income from shares, or other debt obligations not resulting from the right to participate in company profits, as well as income from other corporate rights which, in accordance with the laws of the State of which the resident is a company that performs the distribution of profits, subject to the same taxation treatment as income from shares. 5.2.1 and part 3 of the rules shall not apply if the payment of the actual beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State of which the dividends is resident in the firm's costly using existing permanent representation there, or give independent personal services in the other State through a permanent base located there, and where participation, which is paid out in dividends, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. 6. If company-a resident of a Contracting State derives profits or income, in the other Contracting State, that other State may not impose any taxes or these companies paid dividends, except where the dividends are paid to a resident of the other State, or if the participation of which is paid out in dividends, is actually related to the permanent representation or permanent base in another country, nor to impose a tax on the profit for the whole of society even If the dividends paid or retained earnings consists in whole or in part from the other country of profit or income. Article 11 interest 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes. 2. However, such interest may be taxed taxes according to relevant national laws in the Contracting State in which they arise, but if this the real beneficiaries of the interest is a resident of the other Contracting State, the tax shall not exceed: (a)) 0 (zero) percent of the total of the interest if the interest of the real beneficiary is a company (other than a partnership); (b)) 5 (five) percent of the total interest in all other cases. 3. in part 2, referred to in part 1 percent taxable only in the Contracting State of which the resident is the true beneficiary where: (a)) the true beneficiary is a Contracting State, a political or administrative unit of local government, incorporated companies or the central bank; (b) in the case of Latvia) the true beneficiary organizations are the following: (i) the Latvian guarantee agency; (ii) any other institution, for which in the course of time mutually agreed by the competent authorities of the Contracting States; (c) in the case of Qatar, real) beneficiary is the following, to the extent its wholly owned Qatar: (i) the Qatari investment authority; (ii) the Qatari holdings; (iii) Pension Fund of Qatar; (iv) Qatar Development Bank; and (v) any other institution, for which in the course of time mutually agreed by the competent authorities of the Contracting States. 4. for the purposes of this article, the term "interest" means income from debt claims of every kind, whether or not secured by mortgage and whether or not they have the right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes, which belong to these securities, bonds or debentures. The term "interest" does not include any income which, in accordance with article 10 of the rules of part 4 is considered dividends. The application of the provisions of this article, interest received on time payments, are not considered interest. 5.1, 2 and 3 shall not apply if the interest the real beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located therein, and of claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 6. If the payer of the interest is a resident of a Contracting State, it is considered that the interest generated in this country. However, if the person who paid the interest, 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, which incurred debt obligations, on which the interest is paid, and if such interest is paid (bear) permanent establishment or a permanent basis, it is considered that this interest arises in the State in which the permanent establishment or fixed base. 7. If, on the basis of the special relationship between the payer of the interest and the interest of the true beneficiary, or between both of them and some other person, the amount of interest that relate to debt claims, for which it is paid, exceeds the amount that would have been able to agree to the interest payer and the interest of the beneficiary, if they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the payment of the part which exceeds this amount, taxes are levied according to each Contracting State laws and regulations, taking into consideration other provisions of this agreement. Article 12 royalties 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State taxes. 2. However, such royalties may also impose taxes according to relevant national laws and regulations of the Contracting State in which they occur, but if the real beneficiary of the royalties is a resident of the other Contracting State, the tax shall not exceed 5 (five) per cent of the total royalties. 3. The term "royalties" in this article means payments of any kind received as a compensation for any literary, artistic or scientific work including cinematograph films, and films, a record or drive, radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or the right to use, industrial, commercial or scientific equipment or the use of or the right to use it , or for information concerning industrial, commercial or scientific experience. 4. parts 1 and 2 shall not apply if the real beneficiary of the royalties, which is a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent representation of the existing there, or give independent individual services in that other State through a permanent base located there, and if the right or property for which the royalties are paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 or 14. 5. If the payer of the royalties is a resident of a Contracting State, it is considered that the image occurs in the country. If, however, the person paying the royalties, whether or not that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, due to which a duty to pay the royalties, and if the payment of the royalties (bear) the Permanent Mission or a permanent basis, it is considered that the royalties arise in the State in which the permanent establishment or fixed base. 6. If, on the basis of the special relationship between the payer and the true beneficiaries or between both of them and some other person, the amount of the royalties relating to the use, right or information for which it is paid, exceeds the amount that would have been able to single payer and the beneficiary, if they would not have this special relationship, the provisions of this article are applied only to the latter amount. In this case, the portion of the payment that exceeds this amount, is taxed in accordance with the national laws and regulations, in the light of the other provisions of this agreement. Article 13 capital gains 1. Capital gains, by a resident of a Contracting State derives, the disposal referred to in article 6, in the other Contracting State the existing real property, may be subject to taxes in the other country. 2. Capital gains, by a resident of a Contracting State derives disposing shares or any kind of similar, more than 50 (fifty) per cent of their value directly or indirectly from the other Contracting State of an existing property, may be taxed in that other State taxes. However, the conditions mentioned in this paragraph do not apply to part 3 of article 10 of the said authorities and companies. 3. Capital gains that accrued, disposing of property, which is part of the company of a Contracting State to the permanent representation in business property in the other Contracting State, or disposing of property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, established independent personal services, including capital gains from such permanent missions (alone or with the whole enterprise) or of such a permanent disposal base disposal can impose taxes in the other country. 4. Capital gains by the public company, which is used in international traffic of ships or aircraft, shall be forfeited to the use in international traffic of ships or aircraft or disposing of the property, which belongs to the ship or aircraft, is taxed only in the country. 5. Capital gains generated by the disposal of any property that is not 1, 2, 3 and 4, the property is taxable only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. resident of a Contracting State derives income which, in providing professional services or other independent activities are taxable only in that State except in the following circumstances, when such income may be subject to taxes in the other Contracting State: a) if that person the pursuit of its activities shall have regular access to a permanent base in the other Contracting State; in this case, the other Contracting State may impose income taxes, but only to the extent that it is applicable to this permanent base; or (b) if the person staying) in the other Contracting State for a period or periods exceeding in the aggregate 183 (one hundred eighty-three) days in any 12 (twelve) months period, which begins or ends in the tax year; in this case, the other Contracting State to any taxation of the income it can share gained by the person's activities carried out in this country. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as doctors, lawyers, engineers, architects, dentists and accountants of independent operation. Article 15 dependent personal services 1.16, 18, 19, 20 and 21 the provisions of article for the payment of wages and other similar remuneration, by a resident of a Contracting State receives for gainful employment are taxable only in that State unless paid work is not performed in the other Contracting State. If the salaried work is performed in the other Contracting State, the remuneration received for it can impose taxes in the other country. 2. Notwithstanding the provisions of part 1, remuneration which a resident of a Contracting State receives for paid work that is performed in the other Contracting State, be taxable only in the first mentioned State if: (a) the beneficiary) is found in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty-three) days in any 12 (twelve) months period, which begins or ends in the tax year and (b) the remuneration is paid) an employer who is not a resident of the other State, or the name of the employer, and c the remuneration is not paid) (bear) permanent representation or permanent base, used by the employer in the other country. 3. Notwithstanding the preceding provisions of this article, remuneration received for paid work that is being done to a company of a Contracting State in international traffic used the ship or aircraft, can impose taxes in the country. 4. Notwithstanding the preceding provisions of this article, to pay for salaries, allowances and other remuneration received by an airline of a Contracting State or the shipping company's senior managers, who carried out their activities in the other Contracting State, be taxable only in the first country. Article 16 DIRECTORS ' fees directors ' fees and other similar remuneration received by a resident of a Contracting State as the Board of directors or any other similar organ of a company that is a member of the other Contracting State, a resident may be taxed in that other State taxes. Article 17 artists and athletes 1. articles 14 and 15 of the regulations to the income of a resident of a Contracting State as izpildītājmāksliniek, such as a theatre, film, radio or television artist, or a musician, or as an athlete for your individual activities in the other Contracting State may be taxed in that other State taxes. 2. If izpildītājmāksliniek or athlete's income on his individual activity in the area in question is paid rather than izpildītājmāksliniek or athlete himself but to another person, to the following income regardless of the 7, 14 and 15 the provisions of article 1 may be subject to taxes in the Contracting State in which the activity or sports izpildītājmāksliniek. 3. income which a resident of a Contracting State derives from the second Contracting State made this article part 1 and 2 set out in the action, are exempt from taxation in that other State, if the visit to that other State entirely or mainly financed from the first in that country, its political entity or local authority, or it takes the Government of the Contracting States to the agreement on cooperation in the field of culture, or by mutual agreement. Article 18 pensions and annual fees 1. in accordance with article 19 of part 2 of the regulations for pensions and other similar remuneration, and the annual charges received by a resident of a Contracting State for previous paid employment are taxable only in that State. 2. Notwithstanding the provisions of part 1 and part 2 of article 19 of the regulations, a pension, and other similar remuneration, which is paid in accordance with the Contracting State social insurance system is taxed only in the country. 3. The term "annual fees" means a specified amount charged periodically by certain deadlines throughout the lifetime of a certain or determinable period of time under an obligation to make payments against previously received adequate and full consideration in money or money's worth of stuff. Article 19 government service 1 a) for salaries, fees and other similar remuneration, other than a pension and paid by the natural person contracting State or of its political or administrative unit of local government for that State or entity or municipality services are taxable only in that State; (b) However, such salaries), fees and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that other State who: (i) is a national of that other; or (ii) did not become a resident of that other State solely to provide these services. 2. (a) to any pension to which) natural person the cost of Contracting State or of its political or administrative unit of local government, or who is paid from the funds set up for services provided by that person or entity for this country or municipality are taxable only in that State; (b) However, such pension shall be) taxable only in the other Contracting State if the individual is a resident of the other State and national. 3.15, 16, 17, and article 18 shall apply to salaries, wages, and other similar remuneration paid to a pension in respect of services rendered in connection with a Contracting State or of its political or administrative unit of local business. Article 20 teachers and researchers 1. That on the teaching or research work shall receive individual who arrives in a Contracting State, to teach or to deal with the research work of the University, College, Museum, or other recognized that Contracting State for education or scientific authority or official cultural exchange programme and which is just before the arrival in the Contracting State was the second Contracting State a resident of the is exempt from taxation in that country in the first time period of not more than 2 (two) years from the date when this first came to that purpose. 2. part 1 of this article shall not apply to income earned on the research work, if this research work is carried out rather than public interests, but mostly a specific person or persons in private interest. Article 21 students and trainees payments 1 residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State and who was the first resident in that country have come only for the purpose of study or internship, in this country are not taxed, if this source of payment is not in this country. 2. For payments that are not specified in this article, part 1, and with regard to remuneration for independent personal services rendered in the Studio or during the internship, the student, apprentice or trainee is entitled to the same income tax exemptions, incentives or reductions, which are available to the public, which he attends, a resident. Article 22 other income 1. Other income of a resident of a Contracting State which are not mentioned in previous articles of this agreement, regardless of their sources are taxable only in that State. 2. the provisions of part 1 does not apply to income, other than income from article 6 defined in part 2 of the real property, if the income beneficiary who is a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation of the existing there, or give independent personal services in the other State through a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 or 14. Article 23 avoidance of double taxation in the case of Latvia 1, double taxation is avoided as follows: where a resident of Latvia derives income which, in accordance with this agreement may be subject to taxes in Qatar, then, unless national legislation is more favourable provisions, reduce the resident's permit Latvia income tax for an amount equal to the income tax paid in Qatar. These reductions must not, however, exceed that part of the income tax, which is calculated in Latvia before the application of this reduction is attributable to the income which may be taxed taxes in Qatar. 2. in the case of Qatar, double taxation is avoided as follows: where a resident of Qatar making income, which in accordance with the provisions of this Treaty, the taxable Latvia Qatar allows to reduce the resident's income tax on the amount equal to the income tax paid in Latvia, provided that this reduction shall not exceed the portion of the tax that is calculated before the application of this reduction to the income gained in Latvia. 24. Article 1 of the prevention of DISCRIMINATION on the nationals of a Contracting State in the other Contracting State shall not apply to the taxation and related requirements that are different or more burdensome than the taxation or the related requirements in the same circumstances, in particular in the context of residence applies or may apply to the nationals of the other. This provision shall, notwithstanding the provisions of article 1, also apply to persons who do not have one or both of the Contracting States residents. 2. For stateless persons – residents of a Contracting State, any of the Contracting States shall not apply to the taxation and related requirements that are different or more burdensome than the taxation or the related requirements in the same circumstances, in particular in the context of residence applies or may apply to nationals of the country concerned. 3. Taxation the company of a Contracting State to the permanent representation the other Contracting State may not be less favourable than those of other taxation public companies which perform the same operation. This provision should not be interpreted that it imposes on the Contracting State the obligation to grant the other Contracting State any personal relief to residents, discount and reduction in relation to taxation, which this country give its residents, in the light of their civil status or family responsibilities. 4. Except where the applicable part 1 of article 9, article 11 part 7 or article 12 part 6 rules, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident by establishing this company's taxable profit must be deducted subject to the same provisions as if they were to be paid to the first residents of that State. 5. the Contracting State whose capital, in whole or in part, directly or indirectly, belongs to one or more residents of the other Contracting State or in full or in part, directly or indirectly control these residents, the first in that country may not be subject to any taxation or any requirements associated with it, which is different from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or which is more burdensome for them. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind and name. 7. The Qatari nationals not taxation according to the Qatari national tax laws and regulations will not be considered discriminatory in accordance with the provisions of this article. 25. Article 1 mutual consultation procedures. If a person believes that one or both of the Contracting States concerning this person causes or will cause the taxation which does not comply with the terms of this agreement, that person may, irrespective of the country in national legislation that remedies to submit complaints to the competent authority of the country of which the person is resident, or if the complaint refers to part 1 of article 24, the competent authority of the country of that national is that person. The complaint shall be submitted to the 3 (three) years from the first notification of the action which led to the terms of this agreement without corresponding taxation. 2. If the competent authority deems the complaint to be justified and even fail to reach a satisfactory solution, it will endeavour to agree with the other Contracting State, the competent authority, to prevent the contract inappropriate taxation. Any such agreement is reached is due irrespective of the Contracting State's national laws and the established time limits. 3. the national competent authorities should seek mutual agreement resolve any difficulties or eliminate doubts which may arise in the interpretation or application of this agreement. They may also consult to avoid double taxation in this contract in the event of unforeseen circumstances. 4. in order to reach agreement on these issues in the preceding subparagraph, the competent authorities of the Contracting States may communicate directly with one another, as well as the use of competent authorities or their representatives through the Commission. Article 26 exchange of information 1. Contracting States must be made to the competent authorities information that is expected in this important Treaty provisions or national legislation or the administration requirements for the type and name of all taxes imposed in the Contracting State, its political and administrative units or local authorities, insofar as such taxation is not contrary to this agreement. 1 and 2 of the Treaty, article does not limit the exchange of information. 2. in accordance with the format set out in part 1, any information received by a Contracting State, should be considered as sensitive as information that is obtained in accordance with the laws of this State, and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the above part 1 tax calculation or collection, enforcement or trials or appeals. 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. 3. In any case, part 1 and 2 of the rules must not be explained so that they bind the Contracting State the obligation: a to carry out administrative measures), which does not comply with one or other of the contracting national legislation and administrative practice; (b)) to provide information that is not available under one or the other national legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or process a transaction, or to provide information, the disclosure of which would be contrary to public order (order public). 4. If a Contracting State in accordance with this article shall be required to provide the information to the other Contracting State should use its information gathering measures to obtain the requested information, even if it is considered that the information requested in the other country would not need their taxation requirements. The obligation referred to in the preceding sentence is subject to the restrictions of part 3, but in any case, these limits must not be explained so that they Contracting State permission, refuse to provide information only because it is not national interests with regard to this information. 5. in no case shall the provisions of paragraph 3 may not be explained so that they allow a Contracting State subject to provide information solely because the information is the holder of a bank, another financial institution, agent, or person acting on the authorisation or trust, or because it relates to ownership in person. Article 27 diplomatic missions and consular STAFF to this Agreement shall not affect the diplomatic missions or consular posts personnel fiscal privileges which it applied in accordance with international law, the General rules or specific agreement terms. 28. Article 1 of the LIMITATION of benefits regardless of other articles of this agreement to that Contracting State a resident of the other Contracting State shall not be granted in this agreement, certain relief tax reductions or exemptions, if the resident or persons related to it the main purpose or one of the main goals has been to use this treaty benefits. 2. the provisions of part 1 does not apply to the institutions and units listed in part 3 of article 10. Article 29 entry into force 1. Contracting States through diplomatic channels in writing inform each other that have met their legal procedures laid down for the entry into force of this Treaty. The contract shall enter into force on the date of receipt of the latter notification. 2. the provisions of this agreement, the two Contracting States shall apply: (a)) in respect of taxes withheld at the time the cost of ieskaitītaj amounts paid or from the first day of January or after the calendar year following the year in which the agreement enters into force; and (b)) in the case of other taxes, payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the agreement enters into force. Article 30 termination this agreement is effective until terminated by the Contracting State of its operations. Each Contracting State may terminate the agreement, after 5 (five) year period from the entry into force of this agreement the end date, through diplomatic channels, by giving written notice of termination at least 6 (six) months prior to any of the calendar year following the end of that period. 2. This contract is in both Contracting States shall cease: (a)) in respect of taxes withheld at the time the cost of ieskaitītaj amounts paid or from the first day of January or after the calendar year following the year in which the notice is given; and (b)) in the case of other taxes, payable for any taxation year that begins on the first day of January or after the calendar year following the year in which the notice is given. In witness thereof, the undersigned, being duly authorised, have signed this agreement. Drawn up in New York in two originals in 2014 on September 26, every Latvian, Arabic and English, in addition, all texts being equally authentic. Different case is decisive for the interpretation of the text in English.
The Government of the Republic of Latvia in Edgar Rinkēvič Minister for Foreign Affairs of Qatar, on behalf of the Government of Ahmed bin Jasim Al Thani Minister of Economic Affairs agreement BETWEEN the Government OF the REPUBLIC OF Latvia AND the Government OF the State OF QATAR FOR the avoidance OF double TAXATION AND the PREVENTION OF FISCAL EVASION WITH RESPECT TO taxes ON income the Government of the Republic of Latvia and the Government of the State of Qatar , An agreement the conclud (menu Rngton Line4) for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income, have agreed as follows: article 1 PERSONS COVERED this Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 taxes COVERED 1. This agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespectiv of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovabl property. 3. The existing taxes to which the agreement shall apply in particular to: (a)) in the case of the Republic of Latvia: (i) the enterprise income tax (income tax of enterprises); and (ii) the personal income tax (will tax revenue); (hereinafter referred to as "Latvian tax"); and (b)) in the case of the State of Qatar: (i) the tax on income; (hereinafter referred to as "the Qatari tax"). 4. The agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify the other of any each significant changes that have been made in their taxation laws. Article 3 GENERAL DEFINITION 1. For the purpose of this agreement, unless the context otherwise requires: a the term) "Corporation" 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; (b)) the term "Qatar" means, the State of Qatar and, when used in the sense, location means the State of Qatar ' 's land, internal waters, territorial sea including its bed and sub soil, the air space over them, the exclusive economic zone and the continental shelf, over which the State exercises sovereign rights of Qatar and jurisdiction in accordanc with the provision of international law and national law and Qatar's ' regulations; (c)) the terms "a Contracting State" and "the other Contracting State" mean Latvia or Qatar, as the context requires; (d) the term "person") includes an individual, a company and any other body of persons; e the term "company") means any body corporate or any entity which is treated as a body corporate for tax purpose; (f) the term ") enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; h) the term "competent authority" means: (i) in the case of Latvia, the Ministry of finance or its authorised representative, and (ii) in the case of Qatar, the Ministry of finance, or its authorized representative; (I) the term "national") in relations of a Contracting State means: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership or association deriving its status as such from the law in force in that Contracting State. 2. As regards the application of the agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purpose of the taxes to which the agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State. Article 4 resident 1. For the purpose of this agreement, the term "resident of a Contracting State" means: (a)) in the case of Latvia, any person who, under the laws of Latvia, 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 the Republic of Latvia and any local authority or statutory body thereof. This term, however, does not include any person who is liabl this tax in Latvia in respect only of income from sources in the United States; (b)) in the case of Qatar, any individual who has a permanent home, his center of vital interest, or habitual abode in Qatar, and a company incorporated in Qatar. The term also includes the State of Qatar and any political subdivision, local authority or statutory body thereof. 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 the residence status of an individual cannot be determined in accordanc with the provision of subparagraph (a), (b) and (c)))) above, 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) a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to the settle the question it by mutual agreement. Article 5 permanent establishment 1. For the purpose of this agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a a place of management); (b)) a branch; c) an Office; (d) a factory;) e) a workshop; the premise of the used axis f) sales outlet; g a farm or plantation), and (h)) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploitation of natural resources. 3. The term "permanent establishment" also encompass: (a) a building site, a) a construction, assembly or installation project or a supervisory activity in connection with any such site or project, but only where such site, project or activity continues for a period or periods aggregating more than 6 (six) months within any 12 month period (twelve); and (b)) the furnishings of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if the activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than 6 (six) months within any 12 month period (twelve). 4. Notwithstanding the preceding provision of this article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c)) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d)) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a features or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub paragraphs (a) to (e))), provided that the overall activity of the fixed place of business resulting from this combination is of a features or auxiliary character. 5. Notwithstanding the provision of paragraph 1 and 2, where a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclud-contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertak-for the enterprise , unless the activities of such person with limited it to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provision of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it to one business in the carr a State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carr to one business in that other State (whethers through a permanent establishment or otherwise), shall not of itself either company a permanent constitut establishment of the other. Article 6 income FROM IMMOVABL PROPERTY 1. Income derived by a resident of a Contracting State from immovabl property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovabl property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovabl property, livestock and equipment used in agriculture and forestry, rights to which the provision of general law respecting landed property apply, any option or similar right in their immovabl property, usufruc relations 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, as well as income from the alienation of property immovabl. 4. Where the ownership of shares or other corporate rights in a company the owner of entitl such shares or corporate rights to the enjoymen of immovabl property held by the company, the income from the direct use, letting, or use in any other form of such right may be taxed to the enjoymen in the Contracting State in which the immovabl property is situated. 5. The provision of paragraphs 1, 3 and 4 shall also apply to the income from the immovabl property of an enterprise and to income from the immovabl property used for the performance of independent personal services. Article 7 business profits 1. The profits of an enterprise of a Contracting State shall be only in the taxabl that State unless the enterprise to one business in carr the other Contracting State through a permanent establishment situated therein. If the enterprise on business as aforesaid to carr, the profits of the enterprise may be taxed in the other State but only so much of them as is attributabl to that permanent establishment. 2. Subject to the provision of paragraph 3, where an enterprise of a Contracting State to one business in carr the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which It is a permanent establishment. 3. In determining the profits of a permanent establishment in a Contracting State, there shall be allowed as a deduction in "of which the expense incurred for the purpose of the permanent establishment, including Executive and general administrative expense so incurred, whethers of in the State in which the permanent establishment is situated or which are the allowed elsewher, under the provision of 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 agreement, then the provision of those articles shall not be affected by the provision of this article. Article 8 SHIPPING AND AIR transport 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxabl only in that State. 2. For the purpose of this article, profits of an enterprise from the operation of ships or aircraft in international traffic include: a) profits from the rental on a barebo basis of a ship or aircraft; and (b)) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is it the operations of incidentals ships or aircraft by the enterprise in international traffic. 3. The provision of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 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 if it agree's with the adjustment made by the first-mentioned State. In determining such adjustment, due regard shall be had to the other provision of this agreement and the competent authorities of the Contracting States shall if the cessary not consult each other. Article 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not (a)) 12:0 (zero) per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership); (b)) 5 (five) per cent of the gross amount of the dividends in all other cases. This paragraph shall not be affec the taxation of the company in respect of the profits out of which the dividend is paid with. 3. Notwithstanding the provision of subparagraph (b) of paragraph 2, dividends of) referred to in paragraph 1 shall be the taxabl only in the Contracting State in which the beneficial owner is a resident if: (a) the beneficial owner) is a Contracting State, a political subdivision, a local authority, a statutory body or the Central Bank thereof; (b)) in the case of Latvia, the beneficial owner is one of the following entities: (i) the Latvian guarantee Agency; (ii) any other institution, as may be agreed from time to time between the competent authorities of the Contracting to States; c) in the case of Qatar, the beneficial owner is one of the following entities as long as they want with the wholly owned by Qatar: Qatar Investment Authority (i); (ii) Qatar Holdings, (iii) retirement funds, Qatar (iv) Qatar Development Bank, and (v) any other institution, as may be agreed from time to time between the competent authorities of the Contracting to States. 4. 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 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. 5. The provision of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carr to one business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the holding in respect of which the dividend is paid is effectively connected with such permanent establishment or with a fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 6. 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 undistributed profits of the company ' s, even if the dividends paid or the undistributed profits wholly or partly be consis of profits or income arising in such other State. Article 11 interest 1-interest arising in a Contracting. The State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it «arise and according to the law of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not (a)) 12:0 (zero) per cent of the gross amount of the interest if the beneficial owner is a company (other than a partnership); (b)) 5 (five) per cent of the gross amount of the interest in all other cases. 3. Notwithstanding the provision of paragraph 2, interest referred to in paragraph 1 shall be the taxabl only in the Contracting State in which the beneficial owner is a resident if: (a) the beneficial owner) is a Contracting State, a political subdivision, a local authority, a statutory body or the Central Bank thereof; (b)) in the case of Latvia, the beneficial owner is one of the following entities: (i) the Latvian guarantee Agency; (ii) any other institution, as may be agreed from time to time between the competent authorities of the Contracting to States; c) in the case of Qatar, the beneficial owner is one of the following entities as long as they want with the wholly owned by Qatar: Qatar Investment Authority (i); (ii) Qatar Holdings; (iii) the Retirement Fund of Qatar; (iv) Qatar Development Bank; and (v) any other institution, as may be agreed from time to time between the competent authorities of the Contracting to States. 4. The term "interest" as used in this article means income from debt-claims of every kind, whethers or not secured by mortgage and whethers or not carrying a right to participat in the debtor's profits, and in particular, income from government securities and income from bonds or debentur, including premium and prizes attaching to such securities, bonds or debentur. The term "interest" shall not include any income which is treated as a dividend under the provision of paragraph 4 of article 10. Penalty charges for late payment shall not be regarded as interest for the purpose of this article. 5. The provision of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carr to one business in the other Contracting State in which the interest «arise, through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. 6. Interest shall be deemed the «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whethers he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed the «arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement. Article 12 to 1 to ROYALT Royalt arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may be taxed in royalt also in the Contracting State in which they «arise and according to the law of that State, but if the beneficial owner of the royalt to is a resident of the other Contracting State, the tax so charged shall not exceeds 100 5 (five) 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, tapes or discs for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of , or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provision of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalt, being a resident of a Contracting State, carr to one business in the other Contracting State in which the royalt «arise, through to a permanent establishment 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 14, as the case may be, shall apply. 5. you shall be deemed the Royalt «arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the whethers royalt, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the incurred, and such was the royalt royalt with is borne by such permanent establishment or fixed base, then such shall be deemed to be the royalt «arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalt, having regard to the use, right or information for which they are paid, exceeds 100 for the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship , the provision of this article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain the taxabl according to the law of each Contracting State, due regard being had to the other provision of this agreement. Article 13 CAPITAL gains 1. Gains derived by a resident of a Contracting State from the alienation of property referred to immovabl in article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of shares or of a comparabl interest of any kind deriving more than 50 (fifty) per cent of their value directly or indirectly from immovabl property situated in the other Contracting State may be taxed in that other State. However, the provision of this paragraph shall not apply to the institutions and entities mentioned in paragraph 3 of article 10 3. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 4. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be only in the taxabl you state. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxabl only in the Contracting State of which the alienator is a resident. Article 14 independent PERSONAL services income derived by a 1 resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxabl only in that State except in the following circumstanc, when such income may also be taxed in the other Contracting State: a if he has a fixed) base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributabl to that fixed base may be taxed in that other Contracting State; or b if his stay) in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate the 183 (one hundred and eighty three days) days in any 12 month period (twelve) commencing or ending in the year concerned taxabl; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Article 15 dependent PERSONAL services 1-subject to the provision of articles 16, 18 and 19, salar, WAGs and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxabl only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provision of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be the taxabl only in the first-mentioned State if: a the recipient is present) in the other State for a period or periods not exceeding in the aggregate the 183 (one hundred and eighty three days) days in any 12 month period (twelve) commencing or ending in the taxation 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 4. Notwithstanding the preceding provision of this article, salar, WAGs, and others of the allowance received by an employee remuneration in a top-level managerial position in an airline ora shipping enterprise of a Contracting State , who is stationed in the other Contracting State, shall be the taxabl only in the first-mentioned State. Article 16 DIRECTOR's FEES Director ' ' fe and others of similar remuneration derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. Article 17 artistes AND SPORTPERSON 1. Notwithstanding the provision of articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his capacity as such notes to the accru entertainer or sportsperson himself but to another person, that income may, notwithstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. 3. Income derived by a resident of a Contracting State from the activities exercised in the other Contracting State as envisaged in paragraphs 1 and 2 of this article, shall be exempted from tax in that other State if the visit to that State is supported wholly or other substantially by funds of the first-mentioned State, a political subdivision or a local authority thereof , or the path of the place under a cultural agreement or through a between the Governments of the Contracting States. Article 18 PENSION AND to subject the ANNUIT 1. the provision of paragraph 2 of article 19, and other similar remuneration and retirement annuit to paid to a resident of a Contracting State in considerations of past employment shall be only in the taxabl you state. 2. Notwithstanding the provision of paragraph 1 of this article and paragraph 2 of article 19, and other similar remuneration paid at pension under the social security system of a Contracting State shall be only in the taxabl you state. 3. The term "annuity" means a stated sum payable periodically at stated times during life or during a specified period of time or ascertainabl is under an obligation to make the payments in return for adequat and full considerations in money or money's worth '. Article 19 government service 1 a) and others of the Salar, WAGs similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be only in the taxabl you state. (b) However, such, salar) WAGs and other similar remuneration shall be taxabl only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that other State who: (i) is a national of that other State; or (ii) did not become a resident of that other State solely for the purpose of rendering the services. 2. a Any pension paid by, or) out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be only in the taxabl you state. (b) However, such pension shall be) taxabl only in the other Contracting State if the individual is a resident of, and a national of, that State. 3. The provision of articles 15, 16, 17, and 18 shall apply to salar, and other similar remuneration, WAGs and their pension, in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof. Article 20 teachers AND RESEARCHER. An individual who visits a Contracting State generally for the purpose of teaching or carrying out research at the university, College, Museum or educational or scientific institution, the other recognised or under an official program of cultural exchange 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 2 (two) years from the date of his first visit for that purpose. 2. The provision of paragraph 1 of this article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. Article 21 students AND TRAINE 1. 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. 2. In respect of the payments not covered by paragraph 1 of this article, and remuneration for personal services rendered dependent during such education or training, a student, an apprentice or a trainee shall be entitled to the same relief, exemption or reduction in respect of taxes on income as are available to the residents of the Contracting State he is visiting. Article 22 OTHER income 1-items of income. of a resident of a Contracting State, wherever arising, not deal with in the foregoing articles of this Agreement shall be in the taxabl only a State 2. The provision of paragraph 1 shall not apply to income, other than income from property immovabl as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carr to one business in the other Contracting State through a permanent establishment situated therein, or perform in that other State independent personal services from a fixed base situated therein , and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provision of article 7 or article 14, as the case may be, shall apply. Article 23 ELIMINATION OF double TAXATION 1. In the case of Latvia, double taxation shall be eliminated as follows: where a resident of Latvia's income which, deriv in accordanc with this agreement, may be taxed in Qatar, unless a more favourabl treatment is provided in its domestic law, Latvia shall allow as a deduction in "from the tax on the income of that resident, an amount equal to the income tax paid thereon in Qatar. Such notes shall, however, exceeds 100 Marbles that part of the income tax in Latvia, as computed before the deduction in "is given, which is attributabl to the income which may be taxed in Qatar. 2. In the case of double taxation shall be eliminated Qatar as follows: a where a resident of Qatar's income which, deriv in accordanc with the provision of this agreement, is in Latvia, then taxabl Qatar shall allow as a deduction in "from the tax on the income of that resident an amount equal to the tax paid in Latvia provided that such shall not exceeds 100 Marbles that about of the tax , as computed before the deduction in "is given, which is attributabl to the income derived from Latvia. Article 24 NON-DISCRIMINATION 1-nationals of a Contracting. State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensom than the taxation and connected requirements to which nationals of that other State in the same, in particular with circumstanc respect their residence, may be subjected to or. This provision shall, notwithstanding the provision of article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. a person who with Stateles of residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensom than the taxation and connected requirements to which nationals of the State concerned in the same, in particular with circumstanc respect their residence, may be subjected to or. 3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of the of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowance, relief and reduction for taxation purpose on account of civil status or family responsibilities which it grants to its own residents. 4. Except where the provision of paragraph 1 of article 9, paragraph 7 of article 11, or paragraph 6 of article 12, apply, interest, and other disbursement royalt paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxabl profits of such enterprise, be-deductibl under the same conditions as if they had been paid to a resident of the first-mentioned State. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensom than the taxation and connected requirements to which other similar enterprises of the first-mentioned State may be subjected to or. 6. The provision of this article shall, notwithstanding the provision of article 2, apply to taxes of every kind and description. 7. The taxation of the Qatari national non under Qatari tax law shall not be regarded as discrimination under the provision of this article. Article 25 MUTUAL agreement procedure 1-where a person consider. that the actions of one or both of the Contracting States result or will result for him in taxation not in accordanc with the provision of this agreement, he may, irrespectiv of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or , if his case comes under paragraph 1 of article 24, to that of the Contracting State of which he is a national. The case must be presented within 3 (three) years from the first notification of the action resulting in taxation not in accordanc with the provision of the agreement. 2. The competent authority shall endeavour, if the objection to it appear to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordanc with the agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to the their resolve by mutual agreement any doubt arising as to the difficult or is it the interpretation or application of the agreement. They may also consult together for the elimination of double taxation in cases not provided for in the agreement. 4. The competent authorities of the Contracting States the may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. Article 26 Exchange OF INFORMATION 1. The competent authorities of the Contracting the States shall exchange such information as is foreseeably relevant for carrying out the provision of this agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the agreement. The exchange of information is not restricted by articles 1 and 2. Any information received under paragraph 2 1 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, the determination of the appeal in relations to the taxes referred to in paragraph 1, or the oversigh of the above. 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. 3. In no case shall the provision of of paragraphs 1 and 2 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 (order public). 4. If information is requested by a Contracting State in accordanc with this article, the other Contracting State shall use its information gathering "to obtain the requested information, even though that other State may not need such information for its own tax purpose. The obligation in the preceding line led is subject to the limitations of paragraph 3 but in no case shall such limitations from be construed to permit a Contracting State to supply information to declin solely because it has from the domestic interest in such information. 5. In no case shall the provision of of paragraph 3 be construed to permit a Contracting State to supply information solely to declin because the information is held by a bank, other financial institution, or a person acting in nomine an agency or a fiduciary capacity or because it relate to ownership interests in a person. Article 27 members OF DIPLOMATIC missions AND CONSULAR posts Nothing in this Agreement shall be affec the fiscal privilege of members of diplomatic missions or consular posts under the general rules of international law or under the provision of special agreements. Article 28 LIMITATIONS OF benefits 1. Notwithstanding the provision of any other article of this agreement, (a) a resident of a Contracting State shall not receive the benefit of any reduction in or exemption from tax provided for in this agreement by the other Contracting State if the main purpose or one of the main purpose of such resident or a person connected with such resident was to obtain the benefits of the agreement. 2. The provision of paragraph 1 shall not apply to the institutions and entities mentioned in paragraph 3 of article 10 article 29 ENTRY into force 1. The Contracting States shall notify each other in writing through diplomatic channels of the completion of the procedures required by their law for the bringing into force of this agreement. The agreement shall enter into force on the date of the later of these notifications. 2. The provision of this Agreement shall have effect in both Contracting States: a) with regards to taxes withheld at source, in respect of non paid or credited on or after the first day of January of the calendar year immediately following the year in which the agreement enter into force; and (b)) with regards to other taxes, in respect of taxation years beginning on or after the first day of January of the calendar year immediately following the year in which the agreement enter into force. Article 30 TERMINATION this agreement 1 shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the agreement, through diplomatic channels, by giving written notice of termination at least 6 (six) months before the end of any calendar year following the expiration of a period of 5 (five) years from the date of its entry into force. 2. This agreement shall cease to have effect in both Contracting States: a) with regards to taxes withheld at source, in respect of non paid or credited on or after the first day of January of the calendar year immediately following the year in which the notice is given; and (b)) with regards to other taxes, in respect of taxation years beginning on or after the first day of January of the calendar year immediately following the year in which the notice is given. In witness whereof, the undersigned, duly authorised the theret, have signed this agreement. Done in duplicate at New York the twenty sixth day of September 2014, in the Latvian, Arabic and English languages, all texts being equally authentic. In the case of any divergenc the English text shall prevails.
For the Government of the Republic of Latvia by the Minister of Rinkēvič Edgar Foreign Affairs For the Government of the State of Qatar Ahmed bin Al Thani Minister of Jass's Economics


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