The Saeima has adopted and the President promulgated the following laws: the Republic of Latvia and the Republic of Estonia to the Convention on the avoidance of double taxation and income and capital tax evasion prevention article 1. 14 May 1993 in Tallinn signed in the Republic of Latvia and the Republic of Estonia to the Convention on the avoidance of double taxation and income and capital tax evasion prevention with this law adopted and approved. 2. article. The law shall enter into force on the date of notification. With the law put referred to in article 1 of the Convention and its translation into Latvian language. 3. article. The Convention shall enter into force on its article 30 on time and in order. The law adopted in 1993 the Saeima on 25 November. The President g. Ulmanis in Riga in 1993. December 1, the Republic of Latvia and the Republic of Estonia to the Convention on the avoidance of double taxation and income and capital tax evasion prevention, the Government of the Republic of Latvia and the Government of the Republic of Estonia, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, agreed to: article 1 scope of the Convention this Convention shall apply to persons that is one or both of the Contracting State party to a national rezidento. Article 2 taxes covered by the CONVENTION (1) this Convention shall apply to taxes on income and capital, imposed by a Contracting State, its political entity or local authority, regardless of the method of collecting the tax. 2. On the income and capital taxes, regarded all taxes charged on total income, capital income or all or part of the capital, also movable or immovable property proceeds of disposal of earned income and capital appreciation. 3. The existing taxes to which this Convention applies, in particular, are the following: (a)) Latvia: (i) the profit tax; (ii) the individual income tax; (iii) the property tax; (hereinafter referred to as "Latvian tax"); (b)) in Estonia: (i) the individual income tax (uksikisik-tulumak); (ii) the corporate income tax (ettevott-tulumak); (iii) the license tax (tegevuslo Mack); (hereinafter referred to as «the Estonian tax»). 4. the Convention will be extended to all identical or substantially similar taxes imposed after the date of signature of the Convention in, supplementing or replacing the existing taxes. The competent authorities of the Contracting States must inform each other of all significant amendments to the tax laws of these countries. Article 3 General definitions 1. If it is not apparent from the text, then another in this Convention: a the term «Latvia») means the Republic of Latvia and, used in a geographical sense, represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the Latvian legislation and international legislation can be implemented in Latvia of rights to the depths of the sea, underground and the natural resources contained therein; (b) the term "Estonia") meaning the Republic of Estonia and, used in a geographical sense, represents the territory of Estonia and any other Estonian territorial waters adjacent to the territories in which, in accordance with Estonian law and international legislation implemented in Estonia the right to the depths of the sea, underground and the natural resources contained therein; (c) the term "person) ' means a natural person, company, or any person as a whole; (d) the concept of the «company») means any United formations or to any entity which, for the purposes of taxation is considered as a United entity; e) concepts «Contracting State» and «enterprise of the other Contracting State the company» represents the company, run by a resident of a Contracting State and the company, run by a resident of the other Contracting State; (f) the concept of «citizen») means: (i) any natural person who is a citizen of a Contracting State; (ii) any legal person, company or association whose status stems from State legislation in force; (g)) the notion of «international traffic» means any transport by sea, air, rail or road transport performed by a company of a Contracting State except where sea, air, rail or road vehicles moving between locations only, the other Contracting State; h) the term "competent authorities ' means: (i) in Latvia: the Minister of finance or his authorised person; (ii) Finance Ministers in Estonia or his authorized person. 2. as regards the application of the Convention, the Contracting State will use any term which is not defined here, unless the context requires otherwise, in its use only in the sense that it is this country's tax legislation in relation to the taxes to which this Convention applies. Article 4 residence 1. For application of 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 his permanent residence, residence, location of the actual management, incorporation (registration: the interpreter.) or by any similar character criteria. However, this term does not include persons who are exempt from taxes in this country, only on their income from sources in that State or in the country located in the capital. The term «resident of a Contracting State "also includes the Government of this country, its political and administrative units, municipalities and the Government, administrative unit, or local government agencies or bodies belonging to it completely, which is constituted under the laws of this State. 2. If, following the provisions of article 1 the natural person is a resident of both Contracting States, then it's status will be determined in the following manner: (a)) this person will be deemed to be resident in the country in which is situated the permanent place of residence; If they have a permanent residence in both States, this person will be considered a resident of the State with which it has the closest personal or economic relations (vital interests); (b)) if it is not possible to determine the country in which that person is a vital interest of the Centre, or if it does not have a permanent residence in one of the two countries, that person will be considered a resident of the country where it is common in the home; c) if that person normally home in both countries or none of them, then it will be considered a resident of the State of which a citizen is a person; (d)) if that person is a citizen in both countries, or any of them, 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 a natural person, is a resident of both Contracting States, then it shall be deemed to be a resident of the State from which the law is clear that person's status as such. Article 5 permanent establishment 1. For the purposes of this Convention the term «permanent establishment» means a location where the business is wholly or partly carried on business. 2. The term «permanent establishment» shall include in particular: (a) the management of the company); b) branch; c) Office; (d) a factory;) e) workshop, f) a mine, an oil or gas extraction sites, quarries or any other place of extraction of natural resources. 3. A building site, construction or Assembly project will be considered a permanent establishment only if such building or design work going on for longer than six months. 4. Notwithstanding the preceding paragraphs of this article, the rules, the term «permanent establishment» shall not include: (a) use of equipment) and only the goods belonging to the storage, viewing and supplies; (b) the goods belonging to the company) and inventory products intended solely for storage, viewing and supplies; (c) the goods belonging to the company) tin stocks of products designed exclusively for processing in the other company. d) permanent site designed exclusively for the purchase of goods or products, or for the collection of necessary information; e) permanent site designed solely to make business arrangements or any other ancillary; f) permanent site designed solely to make a) — e) activities referred to in any combination of them, provided that the overall activity of the preparatory or ancillary nature is. 5. Notwithstanding points 1 and 2 of the regulations where the person is not subject to paragraph 6, the independent agent status, running the business and typically uses its powers to contract the Business Contracting State be considered that this company has a permanent establishment in that State in respect of any activities carried out by this person in this country, except when he is carrying out activities referred to in paragraph 4 of carried out through a permanent site, this permanent place of business cannot be regarded as permanent representations in accordance with the provisions of this paragraph. 6. Will be considered that the company does not have permanent representation in the Contracting State where the company is only doing business in that State through a broker, agent or any other agent of an independent status, in addition, provided that such persons perform their normal business activities. However, if such an agent's activity is carried out completely or almost completely business, they cannot be regarded as independent of the status of the agents in the sense referred to in this paragraph. 7. The fact that the company — resident of a Contracting State controls or is controlled from the society, which is the second resident of a Contracting State, or which carries on business in that other State (via the permanent representations, or in any other way) itself does not turn into one of those companies on the other company's permanent representation. Article 6 INCOME from real property 1. Income for the resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State, may be taxing in the second country. 2. The term «immovable property» have the meaning it has in its legislation of a Contracting State in which the property is located. In any case, this concept will be used to denote the property which belongs to real estate property, the right to exercise rights in respect of immovable property, livestock and equipment used in agriculture and forestry, religion, subject to the provisions of the general legislation on real estate, located on Earth, the real estate uzufrukt and rights to variable or fixed payments for the right to use valid minerals, sources and other natural resources , or for their use. For real estate will not be considered as passenger or cargo ships and aircraft. 3. the provisions of paragraph 1 shall be applied in respect of income derived from real estate direct use, letting or use in any other way, as well as for the profits obtained from the disposal of real estate. 4.1 and paragraph 3 shall be applied also with regard to the income from real property of the company, and also with regard to the income from immovable property, which is used for independent individual services. Article 7 business profits 1. Contracting State company profits will be taxed only in that State unless the enterprise carries on business in the other Contracting State through a permanent representation there. If the enterprise carries on business in that way, the company's profits can be taxing in the second country, but only about the profit relating to the permanent representations. 2. in accordance with the provisions of paragraph 3, if the Contracting State is established in the other Contracting State through a permanent representation located there, in each Contracting State to the permanent representations to be subject to the amount of profit, it would get if it were clearly separate undertaking carrying out identical or similar business, 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 in the deductible 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. If a Contracting State has been the practice to determine the profits attributable to the permanent representations, by company profit-sharing the common principle of proportional by departments, paragraph 2 does not prohibit Contracting State to determine the taxable profit by this principle, as it is usual; However, this distribution method to apply it to the result match the content 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. for the purposes of the application of the previous paragraph, the profits attributed to the permanent representations, each year is to be determined, apply the same method, except where duly justified by the necessity to act otherwise. 7. If the profit includes income type, which dealt with separately in other articles of this Convention, then the provisions of this article shall not affect the other provisions of this article. Article 8 international TRANSPORT 1. Contracting State company profits from the sea, air, rail or road vehicles in international traffic of the use will be taxed only in the country. 2. paragraph 1 of this article, the rules will also apply to a company that deals with maritime, air, rail and road transport, income that is earned from a container (trailer, barge, container transport equipment concerned) use, maintenance or rental, used for the transport of goods or products of international traffic. 3.1 and paragraph 2 shall also apply to profits from participation in a cartel in the Union, total business or international transport company. 9. Article SASKARĪG undertakings 1.) when: (a) the Contracting State Enterprise directly or indirectly participating in the other Contracting State, the company's management, control or it owns part of the company's capital; (b)) the same persons directly or indirectly participating in the management, control or capital of an enterprise of part it owns in the State and at the same time in another company in another Contracting State, and in each case between the two enterprises in their commercial and financial relations are created or established rules that are different from the rules that run between two independent (non-related) enterprises, then any profits that take place between the two independent companies, but above, create the rules affect not grown up, may be included in this corporate earnings and taxed accordingly. 2. where a Contracting State includes in the profits of an enterprise of that State — and taxes accordingly — profits subject to which the company of the other Contracting State has been charged with duties, and this included the profit is the profit that would have been the first company of a Contracting State, if the relationship between the two enterprises had been those which would have been between two totally independent companies, then the other must be made for appropriate corrective tax size that is taxed in the country of this profit second. Article 10 dividends 1-dividends, a company of a Contracting State, a resident of the other Contracting State paid to a resident, will be subject to tax only in the second ai country, if the dividend recipient is: a) the company (other than a partnership); (b) the real owner of dividends); (c)) is the holder of the shares, which represent not less than 25% of the equity and voting rights in the company, which pays dividends. 2. Dividends that are not such, as referred to in paragraph 1, and where the cost of a company which is a resident of a Contracting State, a resident of the other Contracting State, may be taxing in the second country. However, such dividends may also be taxing the Contracting State of which the resident is a company that pays dividends, and in accordance with the legislation of that State, but if the dividend recipient is the true owner of the dividends, the tax may not exceed 15% of the total amount of dividends. The competent authorities of the Contracting States may, by mutual agreement, determine the manner in which this restriction is applied. 3. paragraphs 1 and 2 shall not affect the taxation of the company in respect of the taxable profits from which dividends are paid. 4. The term «dividends» this article represents income from shares or other rights, other than debt obligations, to participate in profits, as well as income from other corporate rights which is subjected to the same taxation procedure as income from shares in accordance with the law of the country in which the resident is a company that performs the distribution. 5. paragraphs 1 and 2 shall not apply if the true owner of the dividends, being a resident of a Contracting State engaged in 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 this second country resident and where participation, which is paid out in dividends, is practically related to the permanent establishment or permanent base. In this case, depending on the circumstances, have to apply article 7 or 14. 6. when the company, which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not be taxing any tax the dividends paid, except when the dividends are paid to a resident of that other State or if participation, which is paid for those dividends, is practically related to the permanent representation or permanent base in another country; not to be subjected to taxation of retained earnings of the company even if the dividends paid or retained earnings composed wholly or partly of profits or income arising in the second country. Article 11 interest 1. interest arising in a Contracting State and paid to a resident of the other Contracting State who is the rightful owner of this interest, are taxed only in that other State. 2. for the purposes of this article, the term «interest» represents income from any type of debt obligations, regardless of their security guarantees, in particular, income from government securities and income from bonds, promissory notes, including bonuses and prizes, which belong to these securities, bonds or debentures. Interest received on the interest cost of the untimely, not be regarded as interest, applying the provisions of this article. 3. the provisions of paragraph 1 shall not apply if the person, the true owner of the interest, which is a resident of a Contracting State, carries on business in the other Contracting State in which the interest using the permanent representation located there, or in the second country provided independent personal services through a permanent base located there, and shows a commitment on the basis of which the interest is paid, is practically related to the permanent representations, or permanent base. In this case, depending on the circumstances, have to apply article 7 or 14. 4. If the special relationship between the payer of the interest and the interest of the owner, or implemented between them and a third person, the amount of interest that relate to debt obligations, on the basis of which it is paid, exceeds the amount which would have been agreed between the payer and the interest owner, implemented in the absence of this special relationship, then this article will be applied in relation to the latter (harmonised, translated.). Such a case, the remaining part of the payment is taxed in accordance with the legislation of each Contracting State, provided that you comply with the other provisions of this Convention. Article 12 ROYALTIES 1. The author of the author's royalties arising in a Contracting State and paid to a resident of the other Contracting State who is the author of the true owner, the fees will be taxed only in the second country. 2. The term «royalties» of the author in context of this article means payments of any kind received as a compensation for the use of any copyright, or for the right to use the copyright for literary, scientific or artistic work, including cinematograph films, any patent, trade mark, 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 and scientific activities and experience. 3. the provisions of paragraph 1 shall not be applied, if the implementation of these duties as owner, a resident of a Contracting State, carries on business in the other Contracting State in which the author's royalties, using the existing permanent representation there, or in the second country independent personal services through a permanent base located there, and if the right or property covered by the author's royalty payments, are virtually linked to the Permanent Mission or base. In these cases, depending on the circumstances, be appropriate in article 7 or 14. 4. If the special relationship between the payer and the author's royalty owners, implemented, or between them and any other third party, the author's royalties, which refers to the rights of use or information beyond the author's royalties in the amount by which the taxable person should have been able to agree and implement owner if they would not have such a special relationship, the provisions of this article will apply only to the last-mentioned author royalties. In such cases, the payment of the part that exceeds this amount will be taxed in accordance with the legislation of each Contracting State, taking into consideration other provisions of this Convention. Article 13 capital gains 1. Income from capital gains, received by a resident of a Contracting State referred to in article 6, in the other Contracting State, the alienation of immovable property may be taxed in that other State, 2. Income from capital gains earned on the property, which form a permanent representation in that part of the commercial units of a Contracting State of which the company uses the other Contracting State, or the income from the property that belongs to a resident of a Contracting State to the permanent base of the second Contracting State established independent personal services, including the disposition of income from the following permanent missions (alone or with the whole enterprise) or of such a disposal of the standing base, may be taxed in the other Contracting State. 3. Income from capital gains, the contracting company that used ships, aircraft, rail and road vehicles in international traffic, of vessels, aircraft, train or vehicle seizures, or a property that is associated with these vessels, aircraft, rail and road transport, or containers (including trailers, barges and equipment for transport of containers), seizures, is taxed only in the country. 4. Income from capital gains on the property, which is different from the 1, 2 and 3 above, the forfeiture of the property, is taxed in the Contracting State of which the resident is the seizure of property. 5. Notwithstanding the provisions of paragraph 4, income from capital gains on the disposition of any property received by a person, who has been a resident of a Contracting State and who has become a resident of the other Contracting State, may be taxed in the first country, where the expropriation takes place at any time in the ten-year period after the date on which the individual ceased to be a resident of the first-named country. Article 14 independent personal services 1. Contracting State resident income from professional services or by other independent activity will be taxed only in the country, except when this person your actions, uses regular access to a permanent base the second Contracting State. If you are using such a permanent base, the income may be taxing the second Contracting State but only to the extent they apply to the permanent base. 2. The term «professional services» includes independent scientific, literary, artistic, educational or teaching activities as well as independent doctors, lawyers, engineers, architects, dentists and accountants the action. Article 15 dependent personal services 1.16, 18 and article 19 of the regulations of wages and other similar remuneration received by a resident of a Contracting State in his work, will be taxed only in the country, if one paid work is not performed in the second Contracting State. If the salaried work is carried out in this way, for it received remuneration may be taxed in the other State. 2. Notwithstanding the provisions of paragraph (I), by 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, if: (a) the beneficiary is the remuneration) another country no more than 183 days in any period of 12 months; (b) the remuneration is paid), the employer, or his right of another person who is not a resident of the other State; (c) the remuneration is not paid) from the Permanent Mission or permanent base, used by the employer in the other country. 3. Notwithstanding the preceding provisions of this article remuneration received for work that is being done on the company — resident of a Contracting State the sea, air, rail or road vehicles, which operate in international traffic, may be taxed in that State. Article 16 DIRECTORS ' fees directors ' fees and other similar charges which are residents of a Contracting State receives as a member of the Board of directors or that any of the companies or other legal persons that are residents of the other Contracting State, a member of the governing body, may be taxed in the other Contracting State. Article 17 artists and athletes 1. articles 14 and 15 of the rules of the income received by a resident of a Contracting State as izpildītājmāksliniek, as, for example, theatre, film, radio or television actor or a musician, or as an athlete for your individual process that is; made in the other Contracting State, may be taxed in that other State. 2. in cases where the artist or athlete's income on his individual activity in this area is paid not the artist or athlete but to another person, that income, apart from articles 14 and 15 of the rules can be taxing the Contracting State to which the izpildītājmāksliniek or athletes. 3.1 and paragraph 2 shall not apply to income derived from activities performed by country artist or sportsman if the visit to that State is wholly or partly funded by the other Contracting State, its political and administrative units, the municipal public funds. In such cases, depending on the circumstances, the income will be taxed under 7, 14 or 15 article. Article 18 pensions in accordance with paragraph 2 of article 19, pensions and other similar remuneration received by a resident of a Contracting State for previous paid employment will be subject to tax only in the country. Article 19 the State DIENESTS1. 1. (a)), which is the remuneration and pension which is paid to a natural person contracting State or of its political or administrative unit of local government for this country, unit, or the municipality provided the dependent personal services, will be subject to tax only in the country. (b)) However, this reward 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; (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 of its political or administrative unit of local government, or what the cost of a Contracting State or of its political or administrative unit, the local Government set up funds for services provided by that person in that State, or local government entity will be taxed only in the country. (b)) However, this pension will be taxed only in the other Contracting State if the individual is this (the second — the interpreter.) A resident of the State and the citizen. 3. remuneration and pensions that are received for services provided in respect of the Contracting State or of its political or administrative unit, a local authority, the business must apply to the 15, 16 and article 18. Article 20 students payments which a student, apprentice receives or trainee residence, study or internship needs that directly before entering in the Contracting State was or is the second resident of a Contracting State and situated in the first mentioned State solely for the purpose of study or placement period, will not be taxed in that State provided that such payments arise outside that State. Article 21 other income 1. resident of a Contracting State other income regardless of their building sites that are not covered in previous articles of this Convention, be taxed only in the country. 2. paragraph 1 shall not be applied in respect of income, other than income from immovable property as defined in paragraph 2 of article 6, if the recipient of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent representation located there, or in the second country independent personal services through a permanent base located there, and if the rights or property of which the income is paid is practical related with the permanent representation or permanent base. In cases, depending on the circumstances, have to apply article 7 or 14. Article 22 capital i. capital, represented in article 6 that real estate, which is the property of a resident of a Contracting State and the other Contracting State, may be taxed in the other State taxes. 2. Capital represented by movable property forming part of the second Contracting State located in the Contracting State of the permanent representation of the company property, or capital represented by movable property that belongs to a resident of a Contracting State to a permanent base in the other Contracting State that is used independent of individual services may be subject to taxes in the other country. 3. the Contracting State company which deals with maritime, air, rail or road vehicles in international traffic, the use of capital, represented by sea, air, rail or road vehicles which carry out transport in international traffic, and by the fact that the property associated with the sea, air, rail and road transport; or containers (including trailers, barges and container transport auxiliary units), which are used in international traffic, will be subject to tax only in the country. 4. All the other Contracting State, a resident of the capital items will be taxed only in the country. Article 23 ELIMINATION of double taxation 1. when residents of a Contracting State derives income (other than income to which article 29) or a resident of a Contracting State owns capital which, in accordance with the 7. The Convention, 14, 15 and 22 of article can be subject to tax in the other Contracting State, the first to that country should be exempted from the income or capital taxation in accordance with this article and the provisions of paragraph 3. 2. where a resident of a Contracting State derives income that is not the income covered by this article, the provisions of paragraph 1 and in accordance with the provisions of this Convention may be taxed in the other Contracting State, the first to that country should be permitted to deduct from the tax, which taxed the earnings of resident, such size that is equal to the tax paid in the other country. These deductions, however, exceed that part of the tax, which is calculated before deductions are being made which relate to the second Contracting State earned income. 3. where in accordance with any of the provisions of this Convention, the Contracting States generated by the resident or his capital is exempt from taxation in that country, despite the fact that State to calculate tax on the remaining income or capital of that resident's part, it may also be taken into account income or capital which are exempt from taxes. Article 24 non-discrimination 1. Prevent nationals of a Contracting State shall not be the second Contracting State subject to taxation or any requirements associated with them that is different or is more burdensome than the taxation or related requirements, which may be or are exposed to the other citizens of the country in the same circumstances. This provision shall, notwithstanding the provisions of article I, shall also apply to persons who do not have one or both of the residents of the Contracting States. 2. Stateless persons who are residents of a Contracting State, any of the Contracting States shall not be subject to taxation or any requirements associated with them that are different or more burdensome than the taxation and connected requirements to which are or may be subject to State concerned in the same circumstances. 3. the State company's permanent representation in that it uses in the other Contracting State, may be taxed in that other State, be less favourable than taxed in the other State companies that do the same type of business. This provision shall not be construed as obliging a Contracting State the obligation to grant the other Contracting State, a resident of any private discounts, exemptions or reductions regarding the taxation of which this country give their residents given their civil status or family responsibilities. 4. Except where the applicable paragraph 1 of article 9, paragraph 4 of article II or of article 12, the provisions of paragraph 4, interest, author royalties and other payments made by the enterprise of a Contracting State in favour of the other Contracting State, a resident of determining the taxable profits of the company, must be deducted from the profit on the same conditions 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 report on the same conditions as if it refers to the first residents of that State. 5. enterprises of a Contracting State, the capital of which is wholly or partly belongs to one or more of the other Contracting State, or the residents of the resident or residents directly or indirectly controlled by the company, the first in that country may not be subject to taxation or any related requirements that differ or are more burdensome on taxes and related requirements, which are or may be exposed to similar companies in the first country. 6. The provisions of this article independently of the provisions of article 2, apply to taxes of every kind. Article 25 mutual conciliation procedure 1. If a person believes that one or both of the Contracting States result or action can lead to the person's taxation, which does not comply with the provisions of this Convention, that person may, irrespective of the internal legislation of these countries the rules governing taxation to prevent this, submit your case to the competent authorities of the country where the person is resident of, or, if necessary, applies to article 24, paragraph 1 of the Member State the competent authorities of which are this person. The case should be submitted for review within three years from the first notification of the action which led to 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 resolution, it should try to solve the question by mutual agreement with the other Contracting State, the competent authorities, taking into account the possible attempt to avoid tax evasion, which are not in accordance with this Convention. Each such agreement is reached must be met regardless of the time limit for the internal law of a Contracting State. 3. the national competent authorities should seek mutual consent in the course of resolving any problems or concerns that may arise in the interpretation or application of this Convention. They may also consult together in order to prevent double taxation in cases not provided for in this Convention. 4. The competent authorities of the Contracting States may communicate directly with one another in order to reach agreement on the question referred to in the previous paragraphs. If it seems appropriate to achieving agreement to share thoughts verbally, the following Exchange may take place through a Commission consisting of the competent authorities of the Contracting States. Article 26 exchange of information 1. National authorities should exchange information, which is necessary for the carrying out of the provisions of this Convention or in the internal law of the Contracting States, the requirements relating to taxes covered by this Convention, the implementation of the provision to the extent these laws are not contrary to this Convention. Article 1 of the Convention does not restrict the exchange of information. Any information received by a Contracting State, should be treated as sensitive as information that is obtained in accordance with the national legislation and may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the The Convention includes in the calculation of tax, withholding, or in appeals. Such persons or authorities must use this information only for the purposes mentioned above. It may disclose this information in a lawsuit or court decisions. 2. in no case shall the provisions of paragraph 1 shall not be construed as obliging 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 the other national legislation or administrative practice; (c)) to provide information that may disclose any trade, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public). Article 27 assistance in tax collection 1. the Contracting States undertake to provide each other assistance the taxpayer's outstanding tax collection, tax in final size is determined in accordance with the law of the country which provides the request to provide assistance. 2. where a Contracting State shall submit the request to provide assistance in the collection of taxes, the collection of which is accepted by the other Contracting State, such taxes will be collected in the other country, in accordance with the law that applies to this second state tax revenues, and as taxes would be levied in the other State taxes. 3. any Contracting State a request for assistance in collection of taxes must be accompanied by a confirmation that the taxpayer's debt is fixed definitively, in accordance with the national legislation. 4. when a Contracting State requested the tax amount is not possible to determine precisely because it is determined in court or in any other way, that State may, to maintain its revenue, ask another Contracting State to take interim action in the preservation of these funds on its behalf, if it is allowed to the second country, in accordance with the second law. If the latter agrees to comply with the request, temporary operations are carried out as the first of this tax debt to that country would be the second country to arrive. 5. a request under the preceding paragraph of this article, the provisions of the Contracting State should be submitted only when it does not have available sufficient property tax to cover the outstanding tax amount. 6. the Contracting State in which the tax is levied in accordance with the provisions of this article, shall be paid to the Contracting State of which the good this tax was levied, the amount of the tax collected, from which, if necessary, less the amount of exceptional costs associated with this collection, referred to in paragraph 7 (b)). 7. as long as the competent authorities of the Contracting States agree on different terms, will be deemed to: (a) the Contracting State) current expenditure incurred in providing assistance shall be borne by that State; b) extraordinary expenses arising in the Contracting State providing assistance shall be borne by the other State, irrespective of the amount of tax is collected on its behalf. In the case where a Contracting State anticipates that extraordinary costs may arise, it should immediately make it known to the second country, and should show the following expenditure possible. 8. for the purposes of this article, the term «tax» means the taxes covered by this Convention, and any related penalties or interest. Article 28 DIPLOMATIC and consular officers nothing in this Convention shall not affect the members of diplomatic missions or consular point of fiscal privileges of the employees, in accordance with the applicable international law or special agreements. Article 29 limitation of BENEFITS regardless of article 11 and 12, paragraph 1 of article 7, paragraph 1 of article 10, paragraph 1 of article 14 of the rules, a legal person, the Contracting State income rezidento part that is formed or is received from the other Contracting State, may be taxed in each country in accordance with national domestic legislation and other provisions of this Convention, if it can reasonably be considered that he has created the first in the country with the main aim to use this rule. Article 30 entry into force 1. After compliance with the constitutional requirements for the entry into force of the Convention, the Governments of the Contracting States must exchange relevant notes. 2. the Convention shall enter into force 30 days after the last notes referred to in paragraph 1 of the date of submission and the rules will be applied: (i) in respect of taxes withheld at the time cost, starting with income gained from the calendar year 1 January or after the calendar year following the year in which this Convention enters into force; (ii) in respect of other taxes on income and capital: starting with taxes payable in any tax year beginning in the calendar year January 1, or pēc1. the January following the entry into force of this Convention. Article 31 termination this Convention shall remain valid as long as the Contracting State to stopped. Each Contracting State may terminate this Convention, through diplomatic channels, submit a written note about the termination of not less than 6 months before any end of the calendar year. In such event, the Convention will be terminated: (i) in respect of taxes withheld at the time cost, starting with income for the calendar year January 1st or after in the year following the year in which the notes in question; (ii) in respect of other taxes on income and capital, starting with taxes payable in any tax year beginning on or after 1 January in the year following the year in which the relevant note. The Convention is drawn up in duplicate in the English, signed may 14, 1993 in Tallinn. Signature in the presence of witnesses, being duly authorised, have signed this Convention: the Government of the Republic of Latvia, the Republic of Estonia on behalf of the Government of the Republic of Latvia, the Republic of Finland, and Ambassador in the Republic of Estonia, the Estonian Prime Minister Mart Laar Anna Stanley