AGREEMENT BETWEEN THE REPUBLIC OF KAZAKHSTAN AND KYRGYZ REPUBLIC

of April 8, 1997

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and on the capital

The Republic of Kazakhstan and the Kyrgyz Republic, being guided by the aspiration to strengthen and develop commercial, scientific, technical and cultural ties between both States and wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and on the capital,

agreed about the following:

Article 1 of 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 or its regional authorities according to the legislation of each of Contracting States, irrespective of method of their collection.

2. All types of tax levied from total of income, from 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 salary fund paid by the companies and also the taxes levied from the income from capital value addition are considered as taxes on the income and on the capital.

3. The existing taxes to which the Agreement extends are in particular:

a) in the Republic of Kazakhstan:

I) tax on the income of legal entities and physical persons;

II) property tax of legal entities and physical persons.

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

b) in the Kyrgyz Republic:

I) income tax and income of legal entities;

II) the income tax from physical persons.

(further referred to as as "The Kyrgyz taxes").

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