The Saeima has adopted and the President promulgated the following laws: For the Republic of Latvia and the Republic of Armenia, of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital article 1. 15 March 2000 in Riga signed in the Republic of Latvia and the Republic of Armenia by the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter the Convention) and 15 March 2000 in Riga signed its Protocol (hereinafter referred to as the Protocol) with this law is adopted and approved. 2. article. The law shall enter into force on the day following its promulgation. With the law put the Convention and Protocol in English and Latvian. 3. article. The Convention and the Protocol shall enter into force in article 28 of the Convention within the time and in order, and the Ministry of Foreign Affairs shall notify the newspaper "journal". The Parliament adopted the law of 25 May 2000. State v. President Vaira Vīķe-Freiberga in Riga, June 7, 2000 in the Republic of Latvia and the Republic of Armenia by the Convention on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital of the Republic of Latvia and the Republic of Armenia on the basis of the desire to develop and strengthen economic, scientific, technical and cultural relations between the two Contracting States, as well as in order to prevent double taxation, tax evasion and to prevent discrimination in taxation with respect to taxes on income and capital have decided to conclude this Convention and agree: (I) the scope of the Convention article 1 scope of the Convention this Convention shall apply to persons of either Contracting State or resident of both Contracting States. Article 2 taxes covered by the Convention (1) this Convention shall apply to taxes on income and on capital, irrespective of their method of collecting levies a Contracting State or its municipalities. 2. On the income and capital taxes, regarded as all taxes, which puts the total income total capital or income or capital, the tax shall be levied with movable or immovable property, the proceeds of disposal of earned income and capital appreciation. 3. The existing taxes to which this Convention applies, in particular, is: (a)) in Armenia: (i) the profit tax;     (ii) the income tax;     (iii) the property tax;     (iv) land tax;     (hereinafter referred to as the Armenian tax); (b)): (i) corporate income tax;     (ii) the individual income tax;     (iii) tax on immovable property;     (hereinafter referred to as the Latvian tax). 4. this Convention shall apply also to any identical or substantially similar taxes on income or capital which, supplementing or replacing the existing taxes will be introduced in a Contracting State after the date of signature of this Convention. Of both national authorities are required to inform each other of any significant amendments to the national legislation of the relevant tax legislation. Part II definitions article 3 General definitions 1. If it is not apparent from the context, otherwise in this Convention: a the term "Contracting State)" and "the other Contracting State" depending on the context represents the Latvia or Armenian; (b)) the concept of "Armenia" means the Republic of Armenia, and, used in a geographical sense, it represents the area, also internal waters, to which the Republic of Armenia exercises its sovereign rights and jurisdiction in accordance with international law and its domestic law; (c)) the term "Latvia" means the Republic of Latvia, and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the legislation of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (d) the term "person") denotes a physical person, the company and any other body of persons; e the term "company") represents any United formations or to any entity which, for the purposes of taxation is considered as a United entity; (f) the term "Contracting Government) of the enterprise" and "enterprise of the other Contracting State" represents the company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; g) the term "international traffic" means any carriage by air performed by Contracting State enterprise, except for the cases when the air transport vehicles move only in the other Contracting State; h) the term "competent authority" means: (i) in Armenia, Minister of Economics and finance or his authorised representative;     (ii) in Latvia, the Ministry of finance or its authorised representative; I) the concept of "citizen" represents: (i) any natural person who is a citizen of a Contracting State;     (ii) any legal person, partnership or association whose status stems from State legislation in force. 2. the application of this Convention at any time by a Contracting State any term will be used that is not defined here, only in the sense that if one is not apparent from the context in which it otherwise during the use of this legislation of a Contracting State in respect of the taxes to which this Convention applies. In addition, any explanation of the term in accordance with applicable tax law will have precedence over this concept of explanations under other law of this State. Article 4 resident 1. In this Convention, the term "resident of a Contracting State" means any person who, in accordance with the national legislation is subject to taxation on the basis of the place of residence, place of incorporation (registration), residence, location of the actual management or any other criterion of a similar nature. The concept also includes the Government of a Contracting State or of its local authorities. But this term does not include any person to whom this country is taxable only on their income from existing sources in that State or on capital situated in that State. 2. Where, in accordance with the provisions of paragraph 1 an individual is a resident of both Contracting States, its status will be determined in the following manner: (a)) this person will be considered to be resident only in the country in which they residence; If you are habitually resident in two countries, this person will be considered only for residents of the State with which it has the closest personal or economic relations (Centre of vital interests); (b)) if it is not possible to determine the country in which that person is a vibrant centre of interests, or if it does not have a permanent place of residence in one of the two countries, that person will be considered only for residents of the country where it is common in the home; c) if that person normally home in both countries or none of them, it will be considered only for residents of the country, of which this person; (d)) if that person is a national of both States or no citizen of this country, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, in accordance with the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the Contracting State the competent authorities shall endeavour to resolve the matter by mutual agreement and determine the mode of application of this Convention to such person. Article 5 permanent establishment 1. In this Convention, the term "permanent establishment" means a fixed place of business of which is wholly or partly carried on business. 2. The term "permanent establishment" includes: (a) the management of the company); b) branch; c) Office; (d) a factory;) e) workshop; and (f)) mine shaft, oil or gas extraction sites, quarries or any other natural resource exploration or mining site. 3. (a)), the Assembly, construction or installation project staffing, or associated monitoring activity will be considered permanent representation only if this construction site, project or activity occurs for more than nine months; (b) Contracting State) shelf area of actions associated with that country's maritime and subsoils and there existing natural resource exploration and exploitation, will be considered an activity carried out in that country by using the existing permanent representations, if such activities exceeds the period or periods in the aggregate 30 days in any 12-month period. 4. Notwithstanding the preceding paragraphs of this article, the provisions of the term "permanent establishment" shall not include: (a) the use of buildings and equipment) only and exclusively the goods belonging to, or for the storage of the products demonstrated or supplies; (b) goods belonging to the company) or article items intended solely for storage, demonstration or delivery; (c) the goods belonging to the company) or article items intended exclusively for processing in the other company. d) permanent site designed exclusively for the purchase of goods or products or information collection needs; e) permanent site designed exclusively for making business arrangements or any other ancillary; f) permanent site designed exclusively for making this point a) to (e)) the activity referred to in any combination thereof, provided that the overall activity of the preparatory or ancillary nature is. 5. Notwithstanding points 1 and 2 of the regulations, if a person not referred to in point 6 of the independent status of the agent running the business and generally Contracting State used its powers to enter into contracts on behalf of this company, be deemed that this company has a permanent establishment in that State in respect of any the person's business activities, except where a permanent place of business used by this person by taking the action referred to in paragraph 4, may not be considered permanent representation in accordance with paragraph 4 of this article. 6. it will be considered that the company does not have permanent representation in the Contracting State where the undertaking is established in that country, only through brokers, sales agent or any other agent of an independent status, provided that such persons perform their normal business activities. 7. the fact that the company is a resident of a Contracting State-controlled company, which is a resident of the other Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way), or is subject to the control of such undertaking itself does not turn into one of those companies on the other company's permanent representation. Part III taxation of income article 6 Income from real property 1. income for the resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State, may be taxing in that other country. 2. the term "immovable property" have the meaning it has in its legislation of a Contracting State in which the property is located. The provisions of this Convention relating to real estate, will be applied also with respect to property which belongs to real estate property, livestock and equipment used in agriculture and forestry, rights to which the general law are attributable to the ground attached to the property, any real estate purchase and sales rights or similar right to acquire real estate, real estate uzurfrukt (use rights) and rights to variable or fixed payments for the right to use valid minerals , sources and other natural resources, or for their use, the right to property, which may be caused by a marine and subsoils and there existing natural resource exploration and exploitation, including the right to participation in the ownership or profit, you can get this property. For real estate will not be considered to be ships, barges and aircraft. 3. paragraph 1 of this article, the rules will be applied in respect of income from real estate direct use, letting or use in any other way, as well as income from the disposal of real estate. 4. If the company's shares or other corporate rights give the holder the right to public use of the property, the income from the direct use, letting or use in any other way can be taxing in the Contracting State in which the immovable property is situated. 5. the following article 1, 3, and 4. the provisions of paragraph 1 shall be applied in respect of income from the company's real estate, as well as for income from real property, which is used for independent personal services. Article 7 business profits 1. Contracting State company profits will be taxed only in that State unless the enterprise carries on business in the other Contracting State through a permanent representation of the existing there. If the enterprise carries on business in that way, the company's profits can be taxing in the other country, but only to the profit which is attributable to that permanent establishment. 2. in accordance with the provisions of paragraph 3, if the Contracting State is established in the other Contracting State through a permanent establishment there, existing in each Contracting State to the permanent representations should the profit that this representation could benefit if the individual is clearly the company that performs the same or similar business activities under the same or similar conditions and works independently from this company. 3. in determining the profits of the permanent representation will be made permanent representation expense deduction from amounts taxable. These expenses may be representations of operational and general administrative expenses incurred by the country in which the permanent establishment or elsewhere. 4. where a Contracting State the profits attributable to the permanent establishment shall be determined by dividing the company's total profit in proportion between its departments, paragraph 2 does not preclude the contracting country as usual to determine the taxable profit by this principle; However, this method of distribution must be used so that the results match the principles contained in this article. 5. On the permanent representation will not be applied the earnings just because it has purchased your business goods or articles. 6. the preceding paragraphs of this article apply to the permanent representation of the attributable profit of each year must be determined by the same method, except when there are sufficient grounds to act otherwise. 7. If the profit includes income type, which is discussed separately in other articles of this Convention, the provisions of this article shall not affect the other provisions of this article. 8. Article 1 of air transport enterprise of a Contracting State to profit from the use of air transport in international traffic will be taxed only in the country. 2. paragraph 1 of this article, the rules also apply to profits from the participation in a pool, joint business or international traffic transportation company, but only to the extent that earnings are attributable to the company's participation in the overall business. Article 9 Associated enterprises where: 1 a) Contracting State the company directly or indirectly participating in the other Contracting State, the company's management or control or it owns part of the company's capital; or (b)) the same persons directly or indirectly participating in the management company of a Contracting State or control or they own in the company's capital and at the same time they are directly or indirectly participating in the other Contracting State, the company's management or control or they own part of the company of the other country's capital, and in any case these two corporate commercial and financial relationships are created or established by the rules that are different from the rules, which will be in force between the two independent (non-related) companies, then any profit that the formation of one of the companies, but the above provisions do not affect the established, can be included in the company's earnings and taxed accordingly. 2. where a Contracting State includes in the profits of an enterprise of that State and, where the taxable profit, in respect of which no other country in the territory of the other Contracting State has been charged with duties, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two companies would have been as exist between two independent companies, the other countries have to make appropriate corrective tax size that is taxed in the other State of this profit. In determining this corrective, account must be taken of other provisions of this Convention and, if necessary, shall be held by the competent authorities of the Contracting States for consultations. Article 10 dividends 1-dividends, a company of a Contracting State a resident of the other Contracting State paid to a resident, can be taxing in that other country. 2. However, such dividends may also be taxing in accordance with the national law of the Contracting State of which the resident is a company that pays dividends, but if the real owner of the dividends is a resident of the other Contracting State, the tax shall not exceed: (a) 5% of the dividend) the gross amount of the dividends if the true owner is a company (other than a partnership) which directly manages at least 25% of the capital in the company, which pays dividends; b) 15% of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividend is paid. 3. The term "dividends" in this article means income from shares or other rights to participate in profits, which is not a debt, as well as income from other rights which, in accordance with its national legislation, which the resident is a company that carries out the distribution of profits, is subject to the same taxation as income from the shares. 4. the following article 1 and paragraph 2 shall not be applied where the real owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment there, existing, or provide other State independent personal services from a permanent base located there, where the company that pays dividends, is the other State residents and where participation, which is paid out in dividends, is actually related to the permanent representation or permanent base. In this case, depending on the circumstances, apply article 7 (business profits) or article 14 (independent personal services). 5. If the company — a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not be nor to any duty of the dividends paid by the company, except when the dividend is paid other residents of this State, or when the participation of which is paid out in dividends, is actually related to the permanent representation or permanent base, located in the other country, nor to retained earnings in the company's undistributed profits, even if the dividends paid or retained earnings consists in whole or in part from the other country of profit or income. Article 11 interest 1. interest arising in a Contracting State and paid to a resident of the other Contracting State, may be taxing in that other country. 2. However, such interest may also be taxing according to national law the Contracting State in which they arise. If the interest owner is implemented on the territory of the other Contracting State, a resident of the tax may not exceed 10% of the total amount of interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State, one where the recipient and the true owner is the Government of the other Contracting State, including local authorities, the central bank or any other this Government completely owned financial institutions as well as percentage that received the second State loans guaranteed by the Government, will not be taxed in the first country. 4. for the purposes of this article, the term "interest" means income from debt claims of any type, regardless of the collateral mortgage and regardless of whether or not they have the right to participate in the debtor's profits, and in particular the income from government securities and income from bonds, promissory notes, including bonuses and awards for these securities, bonds or debentures. Interest received on payments made within that time will not be considered interest covered by this article. 5. the following article 1, paragraph 2 and 3 shall not be applied, if the interest owner will exercise, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent representation of the existing there, or provide this second country independent personal services through a permanent base located there, and the claims on the basis of which the interest is paid is effectively connected with such permanent establishment or fixed base. In this case, depending on the circumstances, apply article 7 (business profits) or article 14 (independent personal services). 6. interest will be deemed to arise in a Contracting State when the payer of the interest is a resident of that State. If, however, the person paying the interest, whether that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which incurred debt obligation, for which the interest is paid, and this interest is paid (bear) permanent establishment or fixed base, will be considered that the interest incurred in the State in which the permanent establishment or fixed base. 7. If, due to the special relationship between the payer and the interest percentage implemented owner or between both of them and a third person interest amount, relating to debt claims, on the basis of which it is paid, exceeds the amount that would have been able to agree to the interest payer and the interest owner will, if implemented, they would not have this special relationship, then the provisions of this article shall be applied only to the last-mentioned amount. In this case, the remaining part of the payment is taxed in accordance with the national provisions, provided that you comply with the other provisions of this Convention. Article 12 Royalties (1) royalties arising in a Contracting State and is paid to residents of the other Contracting State, may be taxing in that other country. 2. However, such royalties may be taxing in accordance with national law of the Contracting State in which it arises. If the true owner of the royalties is a resident of the other Contracting State, the tax may not exceed 10% of the total royalties. 3. The term "royalties" in this article means payments of any kind received as a consideration for the use of any copyright or rights to use any copyright on literary, artistic or scientific work, including cinematograph films and films or recordings of radio or television broadcasting, any patent, trademark, design or model, plan, secret formula or process, or for the industrial, commercial, or scientific equipment, or for the right to use it , or for information concerning industrial, commercial or scientific activity and experience. 4. the following article 1 and 2 of the terms will not be applied where the real owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent representation of the existing there, or in another country provides independent personal services through a permanent base located there, and, if the rights or property of, subject to royalty payments, is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 (business profits) or article 14 (independent personal services). 5. If the payer of the royalties is a resident of a Contracting State, it will be considered that the royalties arise in the country. If, however, the person paying the royalties, whether or not that person is a resident of a Contracting State or not, used in the Contracting State of the existing permanent representation or permanent base located there, which committed to pay the royalties, and the royalties paid to (bear) permanent establishment or fixed base, will be considered that the royalties arise in the State in which the permanent establishment or fixed base. 6. If due to the special relationship between the payer of royalties and royalties shall implement the owner or between both of them and a third person the amount of the royalties relating to the rights of use or information exceeds the amount of royalties that would have been able to implement a single payer and the owner if they would not have this special relationship, then the provisions of this article shall be applied only to the last-mentioned amount. In this case, the payment of the part exceeding this amount are taxed according to each Contracting State law provided that you comply with the other provisions of this Convention. Article 13 capital gains 1. income for the resident of a Contracting State alienates a article 6 (Income from immovable property) for the second Contracting State existing real estate, can be taxing in that other country. 2. income for the resident of a Contracting State alienates the public shares, assets which consist mainly of article 6 (Income from immovable property) that the other contracting country real estate, can be taxing in that other country. 3. Increase (capital) gained on the property, which is an enterprise of a Contracting State in the other Contracting standing representative offices in the country to be used in business ownership, disposal or on property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which created the independent personal services, including disposal gains (capital) of the following permanent missions (alone or with the whole enterprise) or of such a permanent disposal base disposal can be taxing in the other Contracting State. 4. Capital increase for the company of a Contracting State alienates the company used in international traffic, air transport or disposal of the property associated with this means of transport aircraft, shall be taxable only in that State. 5. Capital gains arising on the disposition of any property that differs from the 1, 2, 3, and 4. the property referred to in paragraph 1, shall be taxable only in the Contracting State of which the resident is the seizure of property. Article 14 independent personal services 1. Contracting State residents — physical persons income earned by providing professional services or other independent activities, will be taxed only in the country, except when this person your operational needs using a permanent (regular access to a permanent place of business) in the other Contracting State. If you are using the following permanent base, income can be taxing in the other Contracting State but only to the extent that they apply to this permanent base. Where a resident of a Contracting State: a natural person resident in the other Contracting State for a period or periods exceeding in the aggregate 183 that days in any 12 month period commencing or ending in the fiscal year concerned, shall be considered that this person uses regular access to permanent base in the other Contracting State and the income that accrued on the second country made the above mentioned actions will be applied to this permanent base. 2. The term "professional services" includes independent scientific, literary, artistic, educational or teaching activities as well as doctors, lawyers, engineers, architects, dentists and accountants of independent operation. Article 15 dependent personal services 1. in accordance with article 16 (Directors ' fees), article 18 (pensions) and article 19 (Government service), salaries and other earnings, similar to the remuneration received by a resident of a Contracting State for paid employment, will be taxed only in the country, if one paid work is not performed in the other Contracting State. If a paid work is performed in the other Contracting State, the remuneration received for it can be taxing in that other country. 2. Notwithstanding the provisions of paragraph 1, remuneration which a resident of a Contracting State receives for paid work that is performed in the other Contracting State, be taxed in the first only in that country, provided that: (a)) is a beneficiary in another country for a period or periods that exceed 183 days in any 12-month period that begins or ends in the tax year; and (b) the remuneration is paid) an employer who is not a resident of the other State, or the name of the employer; and c the remuneration is not paid) permanent establishment or fixed base which the employer has in the other State is used. 3. Notwithstanding the foregoing provisions of this article remuneration for work carried out by working on the enterprise of a Contracting State in international traffic the air vehicles can be taxing in the country. Article 16 Directors ' fees directors ' fees and other similar remuneration received by a resident of a Contracting State as a company that is a resident of the other Contracting State, the Board of directors or other similar institutions in the Member States, can be taxing in the other Contracting State. Article 17 artists and athletes 1. Notwithstanding article 14 (independent personal services) and 15 (dependent personal services) Regulations income, the resident of a Contracting State as izpildītājmāksliniek, such as theatre, film, radio or television actor as well as a musician or an athlete for your individual activities in the other Contracting State, may be taxing in that other country. 2. If an artist or athlete's income on his individual activity in the area in question are paid not the artist or athlete but to another person, that income regardless of article 7 (business profits), 14 (independent personal services) and 15 (dependent personal services) rules can be taxing the Contracting State to which the izpildītājmāksliniek or athletes. 3.1 and 2 of this article, the provisions will not apply to income earned on the action taken by a Contracting State or an athlete, an artist if they visit this country wholly or mainly support one or both of the Contracting States or of their local public funds. In this case, the following high income will be taxed taxes only in the Contracting State of which the resident is the artist or athlete. Article 18 pensions in accordance with article 19 (Government service) (2) of the pensions and other similar remuneration (including pensions and other similar remuneration, which is paid under the social security legislation) for previous paid employment received by a resident of a Contracting State will be exempt from taxes only in this country. Article 19 government service 1 a) salary, earnings, and other similar remuneration, other than a pension, and a natural person the cost of Contracting State or its municipalities on State or local services to be taxed only in the country. (b)) However, this salary, earnings, and other similar remuneration will be taxed only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purposes of providing the services. 2. a pension by) any natural person the cost of Contracting State or municipality, or the cost to it of that Contracting State or a local government created funds for services provided by that person or the municipality, this country will be taxed only in the country. (b)) However, this pension will be taxed only in the other Contracting State if the individual is a resident of that other State and the citizen. 3. Salary, earnings, other similar remuneration and pensions received for services rendered in connection with a Contracting State or of its local authorities, the business must apply article 15 (dependent personal services), article 16 (Directors ' fees) and article 18 (pensions). Article 20 students payments which a residence, study or internship needs receives a student, apprentice or trainee who is, or immediately before the arrival of the State was the territory of the other Contracting State, a resident of and located in the first mentioned State solely for the purpose of study or placement period, will not be taxed in that State, if such payments arise outside that State. Article 21 other income 1. previous articles of this Convention shall not featured resident of a Contracting State other income apart from the generation of income will be taxed only in the country. 2. paragraph 1 of this article shall not apply to income, other than income from article 6 (Income from immovable property) defined in point 2 of the real property, if the recipient of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment there, existing or in that other State independent personal services from a permanent base located there, and if the rights or property of which you receive this income is actually related to the permanent representations, or permanent base. In this case, depending on the circumstances, apply article 7 (business profits) or article 14 (independent personal services). Part IV taxation of capital article 22 capital 1. capital represented by article 6 (Income from immovable property) of a resident of a Contracting State referred to in the real estate, which is situated in the other Contracting State, may be taxing in that other country. 2. capital represented by movable property forming part of the other Contracting State, the Contracting State the company's permanent representation in business-use property or capital represented by movable property that belongs to a resident of a Contracting State a permanent base in the other Contracting State, which is used for independent personal services, may be taxing in that other country. 3. Capital represented by the air transport means that a company of a Contracting State in international traffic are used, as well as movable property that belong to the air transport features, will be subject to tax only in that Contracting State. 4. All the other Contracting State, a resident of the capital items will be taxed only in the country. Part v prevention of double taxation article 23 methods for the avoidance of double taxation 1. Armenia double taxation will be avoided in the following manner: (a)) in case the resident of Armenia derives income or owns capital which, in accordance with the provisions of this Convention can be taxing in Latvia, Armenia must permit: (i) reduce the resident's income tax for an amount equal to the income tax paid in Latvia;     (ii) reduce the resident's capital tax on amount equal to the capital tax paid in Latvia. These reductions must not, however, exceed the income tax or capital tax, part of what is calculated before this fall, depending on the circumstances, which is attributable to the income or the capital which can be taxing in Latvia; b) where in accordance with any provisions of this Convention a resident of Armenia gained income or capital he holds is exempt from taxation in Armenia, Armenia can take into account the exempted income or capital, setting the tax rate applicable to income or capital which is liable to tax in Armenia. 2. In Latvia, double taxation will be avoided in the following manner: (a)) in case the resident of Latvia derives income or owns capital which, in accordance with the provisions of this Convention can be taxing in Armenia, the Republic of Latvia unless the internal legislation does not provide more favourable provisions, Latvia must permit: (i) reduce the resident's income tax on the portion of the tax is equal to the income tax paid in Armenia;     (ii) reduce the capital residents a tax on that portion of the tax is equal to the capital tax paid in Armenia. These reductions, however, shall in no case exceed the income tax or capital tax, part of which is calculated in Latvia before the application of this reduction depending on the circumstances, which is attributable to the income or the capital which can be taxing in Armenia; (b)) (a) for the application of this section, if the company) — a resident of Latvia receives a dividend from a company — resident of Armenia and in the Latvian resident company holds at least 10 percent of shares with full voting rights, the tax paid in Armenia be included not only tax that taxed dividends, but also tax, which taxed the public profits from which dividends are paid, the part corresponding to these dividends. Part vi special provisions article 24 non-discrimination 1. prevent nationals of a Contracting State in the other Contracting State shall not be subject to the taxation or any requirements connected therewith which differs from taxation or the related requirements which are or may be exposed to the other citizens of the country in the same circumstances, or which is more burdensome, in particular with respect to residence. This provision notwithstanding article 1 (scope of the Convention) the rules shall also apply to persons who are not party to one or both of the Contracting States of the residents. 2. Stateless persons who are residents of a Contracting State, any of the Contracting States shall not be subject to taxation or any requirements connected therewith which differs from taxation or the related requirements which are or may be exposed to nationals in the same circumstances, or which is more burdensome, in particular with respect to residence. 3. a Contracting State a permanent establishment of the representation used in the other Contracting State may not be taxing in that other country less favourably than would be taxed in the other State companies that do the same type of action. This provision shall not be interpreted so that it would impose a Contracting State the obligation to grant the other Contracting State, a resident of any personal allowances, reliefs or reductions in respect of taxation, which this country give its residents, in the light of their civil status or family responsibilities. 4. Except where the applicable article 9 (associated enterprises), paragraph 1 of article 11 (interest) or paragraph 7 of article 12 (royalties), the provisions of point 6, interest, royalties and other payments made by the enterprise of a Contracting State in the other Contracting State the cost of the resident, in determining the taxable profit of the company, must be deducted from the profits subject to the same provisions as if they were to be paid to the first residents of that State. Similarly, the enterprise of a Contracting State in the other Contracting State debt residents, establishing this company's taxable capital, is to be deducted subject to the same provisions as if they would apply to the first residents of that State. 5. the Contracting State whose capital is wholly or partly belongs to one or more of the other Contracting State residents or that these residents are directly or indirectly controlled by, the first in that country may not be subject to taxation or any requirements connected therewith which differ from the taxation and related requirements, which are or may be exposed to similar to the former State enterprises or which is more burdensome. 6. Notwithstanding article 2 (taxes covered by the Convention) rules, the provisions of this article apply to each type and name. 25. Article 1 mutual consultation procedures. If a person believes that one or both of the Contracting States party to the cause or may cause the person's taxation, which does not comply with the provisions of this Convention, that person may, irrespective of the national legislative provisions which provide to eliminate such taxation, submit your question for consideration by the competent authorities of the country of which that person is resident, or, if the matter relates to article 24 (prevention of discrimination) (1) of the Member State the competent authorities of which are this person. The question to be submitted for review within three years from the first notification of the action that caused the taxation not in accordance with the provisions of this Convention. 2. the competent authorities are obliged to seek to resolve this issue, if it considers that the complaint is justified, and if this institution fail to reach a satisfactory solution, it should try to solve the question by mutual agreement with the other Contracting State, the competent authorities in order to prevent this Convention without the appropriate taxation. Each such agreement is reached must be met regardless of the contracting domestic legislation established time limits. 3. the national competent authorities should seek mutual coordination towards resolving any difficulties or eliminate doubts which may arise in the interpretation or application of this Convention. They may also consult to resolve double taxation cases which are not provided for in this Convention. 4. The competent authorities of the Contracting States may communicate directly with one another in order to reach agreement on the question referred to in the previous paragraphs. Article 26 exchange of information 1. National authorities should exchange information necessary for the carrying out of the provisions of this Convention or of the domestic legislation of the Contracting States of the Act concerning taxes covered by this Convention, in so far as for enforcement, these laws are not contrary to this Convention. Article 1 of the Convention (scope of the Convention) does not restrict the exchange of information. Any information received by a Contracting State, should be treated as sensitive as information that is obtained in accordance with the national legislation and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the taxes to which this Convention applies, in the calculation of the collection, the use of coercive measures, 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. 2. in no case shall the provisions of paragraph 1 shall not be interpreted so that they bind the Contracting State the obligation: a to carry out administrative measures), which does not match with the one or the other national legislation or administrative practice; (b)) to provide information that is not available under one or other of the Contracting State legislation or administrative practice generally applicable; (c)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to the public interest (ordre public). 3. The competent authorities of the Contracting States may conclude additional agreement to determine the application of the provisions of this article. Article 27 diplomatic and consular personnel, nothing in this Convention must not be affected by the diplomatic missions or consular posts personnel fiscal privileges which the then applicable under general international law provisions or special agreements. Part VII final provisions article 28 entry into force 1. Contracting States shall notify each other that the constitutional requirements of these countries, which are required for the Convention to enter into force. 2. this Convention shall enter into force referred to in paragraph 1 the last date of submission of the communication, and the rules of both Contracting States shall be applied: (a)) in respect of taxes withheld at the time cost, starting with income for the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force; (b)) in respect of other taxes on income and capital, starting with taxes payable in any tax year that begins on the first day of January or after the first day of January in the calendar year following the year in which this Convention enters into force. Article 29 termination this Convention shall remain valid as long as the contracting party terminates its activities. Each Contracting State may terminate this Convention, diplomatic way by submitting a written note about the termination at least six months before the end of the calendar year following the three-year period to the Convention after its entry into force. In this case the Convention in both Contracting States will end: a) in respect of taxes withheld at the time cost, starting with income for the first day of January or after the first day of January in the calendar year following the year in which the notes in question; (b)) in respect of other taxes on income and capital, starting with taxes payable in any tax year that begins on the first day of January or after the first day of January in the calendar year following the year in which the relevant note. This, the undersigned, being duly authorised, have signed this Convention. Convention concluded in Riga 15 March 2000 in two copies, each of them Latvian, Armenian and English. All three texts being equally authentic. Different case is decisive for the interpretation of the text in English.  
On behalf of the Republic of Latvia, the Republic of Armenia Parker Smith of Vartan Oskanjan Protocol for Signature by the Republic of Latvia and the Republic of Armenia, of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, the parties have agreed upon the following provisions, which are an integral part of the Convention. 1. as regards article 4 (resident) 3: it is understood that, if not agreed between the Contracting States, the competent authorities of such a person in any of the Contracting States shall not be deemed to be a resident of the other Contracting State. 2. in respect of article 7 (business profits) 3: it is understood that the expenses that Contracting State permission to deduct, include only expenses that are deductible under the domestic laws of that State. This, the undersigned, being duly authorised, have signed this Protocol. Protocol, drawn up in Riga, March 15, 2000 in two copies, each of them Latvian, Armenian and English. All three texts being equally authentic. Different case is decisive for the interpretation of the text in English.  
On behalf of the Republic of Latvia, on behalf of the Republic of Armenia Vartan is a Parker Smith Oskanjan