The convention between the Government of the Republic of Uzbekistan and the Government of Georgia on avoidance of double taxation and prevention of tax avoidance on the income (profit) and on property

of May 28, 1996

The government of the Republic of Uzbekistan and the Government of Georgia, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance on the income (profit) and on property, and also for the purpose of development and strengthening of economic cooperation between two countries,

agreed as follows:

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 (profit) and on property levied on behalf of the Contracting State or its local authorities irrespective of method of their collection.

2. All taxes levied from total income (profit) or from part including taxes on the income (profit) on alienation of personal or real estate and taxes on the total amounts of the salary or remunerations paid by the companies belong to taxes on the income (profit) and on property.

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

a) in relation to the Republic of Uzbekistan:

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

(ii) the income tax from citizens of the Republic of Uzbekistan, foreign citizens and stateless persons; and

(iii) property tax;

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

b) in relation to Georgia:

(i) income tax (income) of the companies;

(ii) the income tax from physical persons;

(iii) property tax;

(further referred to as as "taxes of Georgia").

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

Article 3. General determinations

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

a) the term "Uzbekistan", means the Republic of Uzbekistan and in geographical sense covers all 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;

b) the term "Georgia", means Georgia and in geographical sense covers all territory of Georgia which is in frontiers of Georgia including internal and territorial waters, and also exclusive economic zone and the continental shelf to which according to international law and the national legal system of Georgia extends or in the future jurisdiction, the sovereign rights and, respectively, action of the tax legislation of Georgia can extend;

c) the terms "Contracting State" and "other Contracting State" mean the Republic of Uzbekistan and Georgia depending on context;

d) the term "person" means physical person, the legal entity or any consolidation of persons;

e) the term "company" means any company, corporate consolidation, or any organization which for the purposes of the taxation is considered as corporate consolidation, including joint-stock company, limited liability company, joint business, partnership, either any other legal entity or the organization who are assessed with taxes on the income (profit);

f) the term "company of the Contracting State" and "company of other Contracting State" means respectively the company operating under control of resident of the Contracting State and the company operating under control of resident of other Contracting State;

g) the term "international delivery" means any transportation sea, the aircraft, railway or the automotive vehicle used by the company of one Contracting State, except for, when sea, the aircraft, railway or the automotive vehicle is used separately between the Items located in the territory of other Contracting State.

h) the term means "competent authority":

in relation to the Republic of Uzbekistan - the Chairman of the State Tax Committee of the Republic of Uzbekistan or his authorized representative;

in relation to Georgia - the Minister of Finance or his authorized representative;

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