LAW OF THE REPUBLIC OF KAZAKHSTAN

of January 30, 2015 No. 283-V ZRK

About ratification of the Agreement between the Government of the Republic of Kazakhstan and the Government of the State of Qatar about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the Protocol to the Agreement between the Government of the Republic of Kazakhstan and the Government of the State of Qatar about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

Ratify the Agreement between the Government of the Republic of Kazakhstan and the Government of the State of Qatar on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the Protocol to the Agreement between the Government of the Republic of Kazakhstan and the Government of the State of Qatar about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, made in Astana on January 19, 2014.

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE STATE OF QATAR

of January 19, 2014

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

The government of the Republic of Kazakhstan and the Government of the State of Qatar, wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, 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 central or regional authorities irrespective of method of their collection.

2. All types of tax levied from total of income or from separate elements of the income are considered as taxes on the income.

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

a) in case of the Republic of Kazakhstan:

(і) corporate income tax and

(іі) the individual income tax (further referred to as as "The Kazakhstan tax"); and

b) in case of the State of Qatar:

income taxes

(further referred to as as "Qatar tax").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after the date of entry into force of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in the tax legislation of the state.

Article 3. General determinations

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

a) the term "Kazakhstan" means the Republic of Kazakhstan and when using in geographical sense the term "Kazakhstan" includes the state territory of the Republic of Kazakhstan and zone in which Kazakhstan performs the sovereign rights and jurisdiction, according to its legislation and international agreements which participant he is;

b) the term "Qatar" means the State of Qatar and when using in geographical sense the term "Qatar" includes the territory of the State of Qatar, internal waters, the territorial sea, including its bottom and subsoil, airspace over them, exclusive economic zone and the continental shelf on which the State of Qatar performs the sovereign rights and jurisdiction, according to provisions of international law and the national legal system and regulations of Qatar;

c) the terms "Contracting State" and "other Contracting State" mean Kazakhstan or Qatar, depending on context;

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

e) the term means "competent authority":

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

(ii) in case of the State of Qatar: Ministry of Economics and finance or his authorized representative;

f) the term "company" is applied to implementation of any business activity;

g) 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;

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