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The agreement between the Republic of Tajikistan and the Republic of Armenia on avoidance of double taxation and prevention of tax avoidance on the income and on property

of June 30, 2005

Republic of Tajikistan and Republic of Armenia,

being guided by the aspiration to develop and strengthen economic, scientific and technical and cultural cooperation between both States and for the purpose of elimination of double taxation on the income and on property, decided to sign this agreement and agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are residents of one or both Contracting States.

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income and on property levied on behalf of one of Contracting States or its administrative-territorial divisions, or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income on the total amount of property, or from their separate elements, including taxes on the income from alienation of personal or real estate, taxes levied from the total amount of the salary or salary paid by the companies and also the taxes levied from the income from property surplus are considered as taxes on the income and on property.

3. The existing taxes to which the Agreement extends are in particular:

a) in the Republic of Tajikistan:

- tax on the income of legal entities;

- the income tax from physical persons;

- the property tax of legal entities and physical persons (further the referred to as "Tajik taxes");

b) in the Republic of Armenia:

- income tax;

- income tax;

- the property tax (further the referred to as "Armenian taxes").

4. The agreement is applied also to any identical or in essence to similar taxes which will be levied after signature date of this agreement in amendment or instead of the existing taxes. At the end of every year competent authorities of Contracting States will notify each other on any essential changes made to their corresponding tax legislations.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

a) the terms "Contracting State" and "other Contracting State" mean, depending on context, Tajikistan or Armenia.

b) the term "Tajikistan" means the Republic of Tajikistan and when using in geographical sense includes its territory, internal waters, airspace over them where the Republic of Tajikistan can perform the sovereign rights and jurisdiction, including the rights on use of subsoil and natural resources according to rules of international law and where the legislation of the Republic of Tajikistan is effective;

c) the term "Armenia" means the Republic of Armenia;

d) the term "person" includes physical person, the company and any other consolidation of persons;

e) the term "company" means any corporate education, or any other consolidation which for the purposes of the taxation is considered as corporate education;

f) the terms "company of the Contracting State" and "company of other Contracting State" mean, respectively, the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

g) the term "international delivery" means any transportation sea or the aircraft, railway or road transport operated by the company of the Contracting State except cases when sea or the aircraft, rail or road transport is operated only between Items in other Contracting State;

h) the term "national person" means:

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association who received the status according to the current legislation of the Contracting State;

I) the term means "competent authority":

(i) in the Republic of Tajikistan - the Ministry of Finance or its authorized representative;

(ii) in the Republic of Armenia - the Minister of Finance and Economy of the Republic of Armenia and the chief of the State Tax Administration under the Government of the Republic of Armenia or their authorized representatives.

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