AGREEMENT BETWEEN THE GOVERNMENT OF THE KYRGYZ REPUBLIC AND GOVERNMENT OF MONGOLIA

of December 4, 1999

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

The government of the Kyrgyz Republic and the Government of Mongolia, being guided by the aspiration to develop and strengthen economic, scientific and technical and cultural cooperation between both States and for the purpose of elimination of double taxation of the income and the capital, decided to sign this agreement and 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 and the capital levied according to the legislation of each of Contracting States irrespective of method of their collection.

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

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

a) in the Kyrgyz Republic:

- the income tax and the income from legal entities;

- the income tax from physical persons;

(further the referred to as "Kyrgyz taxes");

b) in Mongolia:

- the income tax and the income from legal entities;

- the income tax from physical persons;

(further the referred to as "Mongolian taxes").

4. This agreement is also applied to any identical and 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 shall 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 of the term "Kyrgyzstan" means the territory 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:

b) the term "Mongolia" in geographical sense means, the territory of Mongolia and any other territory in which by the legislation of Mongolia and according to international law, Mongolia can perform the sovereign rights concerning natural resources;

c) the term "person" includes physical person, the company and any other consolidation; d) the term "company" means any corporate consolidation, or any other organization which for the purposes of the taxation is considered as corporate consolidation, and includes, in particular, joint-stock company, limited liability company, either any other legal entity or the organization;

e) the terms "Contracting State" and "other Contracting State" mean Mongolia or the Kyrgyz Republic, 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 by the aircraft, the railway or road transport operated by the company of the Contracting State except cases when the aircraft, the rail or road transport is operated only between Items in other Contracting State;

h) the term means "competent authority":

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

2. in Mongolia - the Minister of Finance or the representative authorized by him; i) the term "citizen" means:

1. any physical person having nationality of the Contracting State;

2. any legal entity, partnership or any other association who received the status according to the current legislation of the Contracting State;

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