The convention between the Republic of Kazakhstan and the Republic of Estonia on avoidance of double taxation and prevention of tax avoidance on the income and on the capital

of March 1, 1999

The Republic of Kazakhstan and the Republic of Estonia, wishing to sign the Convention on avoidance of double taxation and prevention of tax avoidance on the income and on the capital,

agreed as follows:

Article 1 of Person to which the Convention is applied

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 is applied to the taxes on the income and the capital levied on behalf of the Contracting State or its regional authorities 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, and also capital gain taxes are considered as taxes on the income and the capital.

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

a) in Kazakhstan:

(i) tax on the income on legal entities and physical persons;

(ii) property tax of legal entities and physical persons;

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

b) in Estonia:

(i) income tax (tulumaks);

(ii) local income tax (kohalik tulumaks);

(further referred to as as "The Estonian tax").

4. The convention is also applied to any identical or in essence to similar taxes which will be levied after signature date of the Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes and their corresponding tax legislations.

Article 3 General determinations

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

a) the terms "Contracting State" and "other Contracting State" mean Kazakhstan or Estonia, depending on context;

b) terms:

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