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The convention between the Government of the Republic of Kazakhstan and the Government of the Republic of Armenia on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and on property

of November 6, 2006

The government of the Republic of Kazakhstan and the Government of the Republic of Armenia, wishing to sign the Convention on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and on property,

agreed as follows:

Article 1. Persons to whom the Convention is applied

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

Article 2. Taxes to which the convention extends

1. This Convention is applied to the taxes on the income and on property levied on behalf of the State its central or regional authorities, irrespective of method of their collection.

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

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

in the Republic of Kazakhstan:

a) corporate income tax;

b) individual income tax;

c) the property tax (further referred to as as "the Kazakhstan taxes");

in the Republic of Armenia:

a) income tax;

b) income tax;

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

4. This Convention is applied also to any taxes identical or in essence the similar taxes specified in Item 3 of this Article which will be levied in amendment or instead of the existing taxes after the date of entry into force of this Convention. Competent authorities of the States will notify each other on any essential changes which will happen in national legal systems of the States concerning the taxation.

Article 3. General determinations

1. For the purposes of this Convention the following terms are applied:

a) Kazakhstan - means the Republic of Kazakhstan and when using in geographical sense includes the state territory of the Republic of Kazakhstan and zone in which the Republic of Kazakhstan can perform the sovereign rights and jurisdiction, according to its national legal system and international treaties which participant she is;

b) Armenia - means the Republic of Armenia and when using in geographical sense means the territory, including the earth, waters, subsoil and airspace on which the Republic of Armenia performs the sovereign rights and jurisdiction according to the national legal system and international law;

c) "State" - means, depending on context, Kazakhstan or Armenia;

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

e) "company" - means any corporate education or any economic unit which for the purposes of the taxation are considered as corporate education;

f) "company" - is applied to implementation of any kind of business activity;

g) "the company of the State" and "the company of other State" - mean, respectively, the company managed by resident of the State and the company managed by resident of other State;

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

i) "competent authority" means:

(i) in Kazakhstan: Ministry of Finance of the Republic of Kazakhstan or his authorized representative;

(ii) in 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;

j) "national person" means:

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

(ii) the legal entity, partnership or association which received the status according to the national legal system of the State;

k) "business activity" includes implementation of professional services and other activities of independent nature;

1) "the place of effective management" - means the place of implementation of the main management and adoption of the strategic commercial decisions necessary for carrying out business activity of the legal entity.

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