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AGREEMENT BETWEEN THE GOVERNMENT OF THE KYRGYZ REPUBLIC AND GOVERNMENT OF THE UNITED ARAB EMIRATES

of December 7, 2014

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

Government of the Kyrgyz Republic and Government of the United Arab Emirates,

wishing to develop the mutual economic and financial relations by means of the conclusion among themselves of the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, and also to develop and strengthen economic, scientific, technical and cultural cooperation,

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, its administrative divisions or local authorities irrespective of method of their collection.

2. All taxes levied from total of income or from income elements including taxes on the income from alienation of personal and real estate, taxes on the total amount of the salary or salary paid by the companies are considered as taxes on the income.

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

a) in the Kyrgyz Republic:

- income tax;

- the income tax levied from physical persons (further referred to as as "taxes of Kyrgyzstan");

b) in the United Arab Emirates:

- corporate tax;

- the income tax (further referred to as as "taxes of the UAE").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after signature date of this agreement in amendment or instead of the existing taxes. 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 purpose of this agreement if other does not follow from context:

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

b) the term "United Arab Emirates" when using in geographical sense means the territory of the United Arab Emirates over which it has sovereignty, and also the territory outside territorial waters, airspace and underwater space where the United Arab Emirates perform the sovereign rights and jurisdiction concerning any activities made in their waters on seabed, in connection with use of natural resources according to rules of international law and legislations;

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

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

e) the terms "Contracting State" and "other Contracting State" mean the Kyrgyz Republic and the United Arab Emirates, depending on context;

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;

g) the term "international delivery" means any transportation sea either the aircraft, or the road vehicle operated by the company of the Contracting State except cases when the ocean ship, the aircraft, or the road vehicle is operated only between Items in other Contracting State;

h) the term means "competent authority":

(1) in the Kyrgyz Republic - the Ministry of Economics or its authorized representative;

(2) in the United Arab Emirates - the Ministry of Finance or its authorized representative;

i) the term "given" means:

(1) any physical person having nationality of this Contracting State;

(2) any legal entity, partnership or consolidation which received the status according to the current legislation of this Contracting State.

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