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THE CONVENTION BETWEEN THE REPUBLIC OF UZBEKISTAN AND THE KINGDOM OF BELGIUM

of November 14, 1996

About avoidance of double taxation and prevention of tax avoidance on the income and on the capital

(Protocol as amended of 18.02.2015)

Government of the Republic of Uzbekistan and Government of the Kingdom of Belgium,

wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance on the income and on the capital,

agreed as follows:

Chapter 1 Convention Scope

Article 1 Scope

This Convention is applied to persons who are residents of one or both Contracting States.

Article 2 Taxes to which the Convention extends

1. This Convention extends to the taxes on the income and on the capital levied on behalf of the Contracting State or its local authorities irrespective of method of their collection.

2. All taxes levied from total income on the general capital or from part of the income, or from part of the capital, including taxes on the income from alienation of personal or real estate and taxes on the total amounts of the salary or salaries paid by the companies and also taxes on value increase of the capital belong to taxes on the income and on the capital.

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

a) in relation to the Republic of Uzbekistan:

1 * tax on the income (profit) of the companies, associations and organizations;

2 * the income tax from citizens of the Republic of Uzbekistan, foreign citizens and stateless persons; and

3 * property tax;

(further referred to as as "taxes of Uzbekistan");

b) in relation to Belgium:

1 * income tax;

2 * corporate tax;

3 * the income tax from legal entities;

4 * the income tax from nonresidents;

5 * special collection from the income of movable property;

6 * additional assignments on crisis case, including advance payments, the additional charges from these taxes and advance payments and additional payments to the income tax from physical persons, (further referred to as as "taxes of Belgium").

4. This Convention will be applied also to any identical or in essence to the similar taxes levied after signature date of this Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on "essential" changes in their corresponding tax legislations.

Chapter II of Determination

Article 3 General determinations

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

a) 1 * the term "Uzbekistan", means the Republic of Uzbekistan and when using in geographical sense means the territory of the Republic of Uzbekistan, including territorial waters and air spaces within which the Republic of Uzbekistan can perform the sovereign rights and jurisdiction, including the rights to use the subsoil and natural resources by the legislation of the Republic of Uzbekistan and according to international law;

2 * the term "Belgium", means the Kingdom of Belgium, and when using in geographical sense means the territory of the Kingdom of Belgium, including the territorial sea and any other area in the sea and in airspace where the Kingdom of Belgium according to international law performs the sovereign rights or its jurisdiction;

b) the terms "one Contracting State" and "other Contracting State" depending on context means Uzbekistan or Belgium.

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

d) the term "company" means any corporate education, joint business or any other organization which is considered as corporate education for the purpose of the taxation;

e) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively the company operating under control of resident of one Contracting State and the company operating under control of resident of other Contracting State;

f) the term "international delivery" means any transportation sea, the aircraft or road or railway transport used by the company of the Contracting State, except for, when sea, the aircraft or road or railway transport, are used only between the Items located in the territory of other Contracting State;

g) the term means "competent authority":

1 * in relation to Uzbekistan the Chairman of the State Tax Committee or its authorized representative;

2 * in relation to Belgium, depending on circumstances, the Minister of Finance of Federal government and/or government of the region and/or Community, or his authorized representative; and

h) the term "national person" means:

1 * any physical person having nationality of this State;

2 * any legal entity, partnership or association which received the status, as such by the current legislation of this State.

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