The agreement between the Government of the Kyrgyz Republic and the Government of the Republic of Moldova on avoidance of double taxation and prevention of tax avoidance on the income and on the capital

of April 17, 2004

Government of the Kyrgyz Republic and Government of the Republic of Moldova,

wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance on the income and on the capital and confirming the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation,

agreed as follows:

Article of 1 PERSON To WHICH 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 on the capital levied on behalf of the Contracting State, its administrative divisions or regional authorities according to the current legislation of the Contracting State irrespective of method of their collection.

2. All taxes levied from the total amount of the 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 and on the capital.

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

a) in the Kyrgyz Republic:

(i) income tax and income of legal entities;

(ii) the income tax from physical persons;

(further referred to as as "Kyrgyzstan taxes");

b) in the Republic of Moldova:

(i) income tax;

(ii) non-personal tax;

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

4. The agreement is also applied to any identical and in essence to similar taxes which will be levied after signature date of the 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.

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