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

of October 16, 1997

Government of the Kyrgyz Republic

and Government of Ukraine,

being guided by the aspiration to develop and strengthen economic, scientific and technical and cultural cooperation between both States and for the purpose of elimination of double taxation of the income and property, 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 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 the capital levied according to the legislation of each of Contracting States 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 and real estate, taxes levied from the salary fund, paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income and the capital.

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

a) in the Kyrgyz Republic:

the income tax and income from legal entities;

the income tax from physical persons;

(further the referred to as "Kyrgyz taxes");

b) in Ukraine:

income tax of the companies;

income tax;

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

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

Article 3 General determinations

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

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