The agreement between the Government of the Kyrgyz Republic and the Government of the Russian Federation on avoidance of double taxation and prevention of tax avoidance on the income

of January 13, 1999

The government of the Kyrgyz Republic and the Government of the Russian Federation, being guided by the aspiration to strengthen and develop commercial, scientific, technical and cultural ties between both States and wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance on the income, agreed about the following:

Article 1 of Person to which 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 in each of Contracting States irrespective of method of their collection.

2. As taxes on the income all taxes levied from total income or on separate elements of the income, including taxes on the income from alienation of personal or real estate, taxes levied from the total amount of salary or salary paid by the companies and also the taxes levied from the income from property increase in value will be considered.

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

a) in the Russian Federation:

- income tax (income) of the companies and organizations;

- the income tax from physical persons

(further referred to as as "The Russian taxes");

b) in the Kyrgyz Republic:

- income tax (income) of legal entities;

- the income tax from physical persons

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

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied in addition to the existing taxes or instead of them after signature date of the Agreement. Competent authorities of Contracting States will notify each other on any essential changes which will be 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 term "Russian Federation" means the territory of the Russian Federation, and also its continental shelf and exclusive economic zone;

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

c) the term "person" includes physical person, the company or any other consolidation of persons;

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

e) the terms "one Contracting State" and "other Contracting State" mean the Kyrgyz Republic or the Russian Federation depending on context;

e) the terms "company of one 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, river, the aircraft, railway, road or other transport operated by the company of the Contracting State except cases when such transportation is performed only between Items in other Contracting State;

h) the term "national person" means:

- any physical person having nationality of the Contracting State;

- any legal entity, the company, partnership or any other association which received the status based on the current legislation of the Contracting State;

i) the term means "competent authority":

- in the Kyrgyz Republic: Ministry of Finance or its authorized representative;

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