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The agreement between the Government of the Kyrgyz Republic and the Government of the Republic of Latvia On avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

of December 7, 2006

Government of the Kyrgyz Republic 

Government of the Republic of Latvia

Wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, and confirming the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation, 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 levied on behalf of the Contracting State or its administrative divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income or on separate elements of the income, including taxes on the income from alienation of personal and real estate, and also taxes levied from the income from capital gain are considered as taxes on the income.

3. The existing taxes to which this agreement extends are in particular:

a) in Kyrgyzstan:

(i) income tax and income of legal entities;

(ii) the income tax from physical persons;

(further referred to as as "taxes of the Kyrgyz side").

b) in the Republic of Latvia:

(i) tax on the income on the companies;

(ii) the income tax from physical persons;

(further referred to as as "The Latvian taxes").

4. This agreement is also applied 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. Competent authorities of Contracting States shall notify each other on any essential changes which will be made to their corresponding tax legislations.

Article 3. General determinations

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

a) the terms "Contracting State" and "other Contracting State" are meant by Kyrgyzstan or Latvia, depending on context;

b) the term "Kyrgyzstan" means the Kyrgyz Republic. When using in geographical sense the term "Kyrgyzstan" means the territory in which the Kyrgyz Republic performs the sovereign rights and jurisdiction according to international law and on which the tax legislation of the Kyrgyz Republic acts.

c) The term "Latvia" means the Republic of Latvia and when using in geographical sense means the territory of the Republic of Latvia and any area adjacent to territorial waters of the Republic of Latvia in which according to the Latvian legislation and rules of international law Latvia can perform the rights concerning seabed, its subsoil and natural resources;

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

e) the term "company" means any legal entity or any organization which for the purposes of the taxation is considered as the separate organization;

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

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

h) the term means "competent authority":

(i) in Kyrgyzstan - the Ministry of Economics and finance or his authorized representative;

(ii) in Latvia - the Ministry of Finance or its authorized representative;

i) 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.

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