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AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF TAJIKISTAN AND GOVERNMENT OF THE REPUBLIC OF UZBEKISTAN

of March 9, 2018

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

Government of the Republic of Tajikistan and Government of the Republic of Uzbekistan,

being guided by the aspiration to develop and strengthen economic cooperation between both States,

decided to sign this agreement and agreed as follows:

Article 1 of Person to which the Agreement is applied

This agreement is applied to persons which 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 on behalf of one of Contracting States or its administrative-territorial divisions or regional authorities 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 or real estate, taxes levied from the total amount of the salary or salary paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income (profit) and the capital.

3. In particular, treat the operating taxes to which this agreement extends:

a) in the Republic of Tajikistan:

income tax;

income tax;

non-personal tax;

(further referred to as as "taxes of Tajikistan"),

b) in the Republic of Uzbekistan:

income tax of legal entities;

income tax;

property tax;

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

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

Article 3 General determinations

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

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