LAW OF THE REPUBLIC OF KAZAKHSTAN

of May 31, 2010 No. 284-IV ZRK

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

Ratify the Agreement between the Government of the Republic of Kazakhstan and the Government of the Republic of Finland on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the Protocol to it, made in Helsinki on March 24, 2009.

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE REPUBLIC OF FINLAND

of March 24, 2009

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

Government of the Republic of Kazakhstan and Government of the Republic of Finland,

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 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 including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

3. The existing taxes to which the Agreement extends are:

a) in Kazakhstan:

(i) corporate income tax;

(ii) individual income tax;

(further referred to as as "The Kazakhstan tax");

b) in Finland:

(i) national income taxes;

(ii) corporate income tax;

(iii) municipal tax;

(iv) church rate;

(v) the tax withheld at source from percent; and

(vi) the tax withheld at source from the income of nonresidents;

(further referred to as as "The Finnish tax").

4. The agreement is also applied to any identical or in essence to similar taxes which will be levied after signature date of the Agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in their tax legislations.

Article 3. General determinations

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

a) term:

(i) 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 can perform the sovereign rights and jurisdiction, according to its legislation and international law;

(ii) Finland means the Republic of Finland and, when using in geographical sense, means the territory of the Republic of Finland and any zone adjacent to territorial waters of the Republic of Finland within which by the legislation of Finland and according to international law, Finland can perform the rights concerning investigation and development of natural resources of seabed and subsoil of seabed, and in adjacent waters;

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

c) the term "company" means any corporate education or any economic unit which for the tax purposes is considered as corporate education;

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

e) 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;

f) the term "international delivery" means any transportation sea or the aircraft operated by the company of the Contracting State except cases when sea or the aircraft is operated only between Items in other Contracting State;

g) the term means "competent authority":

(i) in Kazakhstan: Ministry of Finance or its authorized representative.

(ii) B of Finland: The Ministry of Finance, his authorized representative or body which the Ministry of Finance will determine as competent authority;

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