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PROTOCOL

of May 15, 1992

About unification of approach and the conclusion of agreements on avoidance of double taxation of the income and property

According to the Agreement between the governments of the State Parties of the Commonwealth of Independent States on the agreed principles of tax policy of March 13, 1992 (Article 4) and for the purpose of ensuring single methodological approach to the conclusion of agreements on avoidance of double taxation of the income and property Heads of governments of the State Parties of the Commonwealth agreed to use among themselves and with the third countries the standard agreement (is on this matter attached).

It is made in the city of Tashkent on May 15, 1992 in one authentic copy in Russian. The authentic copy is stored in Archive of the Government of the Republic of Belarus which will send to the states which signed the this Protocol, its verified copy.

For the Government of the Republic of Armenia

Signature

For the Government of the Russian Federation

Signature

For the Government of the Republic of Belarus

Signature

For the Government of the Republic of Tajikistan

Signature

For the Government of the Republic of Kazakhstan

Signature

For the Government of the Republic of Uzbekistan

Signature

For the Government of the Kyrgyz Republic

For the Government of Ukraine

Signature

For the Government of the Republic of Moldova

Signature

 

Appendix

to the Protocol on unification of approach and the conclusion of agreements on avoidance of double taxation of the income and property of May 15, 1992

The agreement between the Government ________________ and the Government _______________ about avoidance of double taxation of the income and property.

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

Article 1 of Person to which the Agreement is applied

1. This agreement is applied to persons who are persons with the permanent residence in one or both Contracting States.

2. For the purposes of this agreement the term "person with the permanent residence in one Contracting State" means any person or any education which by the legislation of this State is subject in it to the taxation on the basis of the residence, the permanent residence, place of registration as the legal entity or any other similar criterion.

If the income turns out complete partnership, partnership or fund, the permanent residence of this complete partnership, partnership or fund is determined according to the place of its registration.

3. If according to Item 2 provision person which is not physical person is person with the permanent residence in both Contracting States, it is considered face with the permanent residence in that Contracting State in which its actual governing body is located.

4. If according to Item 2 provision the physical person is person with the permanent residence in both Contracting States, its provision is determined as follows:

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