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

of June 26, 2006

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 Malaysia, wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, agreed about the following:

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 irrespective of method of their collection.

2. All taxes levied from total of income or from separate elements of the income including taxes on the income from alienation of personal or real estate, taxes on the total amount of salary or the 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 Republic of Kazakhstan:

(i) corporate income tax;

(ii) individual income tax;

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

b) in Malaysia:

(i) income tax;

(ii) oil income tax

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

4. This agreement is also applied to any identical or in essence to similar taxes on the income which will be levied after signature date of this agreement in addition to the existing taxes or instead of them. Competent authorities of Contracting States will notify each other on any essential changes which will happen in their legislations concerning the taxation.

Article 3. General determinations

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

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