LAW OF THE REPUBLIC OF KAZAKHSTAN

of May 31, 2010 No. 284-IV ZRK

About ratification of the Agreement between the Government of the Republic of Kazakhstan and the Government of the Republic of Finland about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the Protocol to it

Ratify the Agreement between the Government of the Republic of Kazakhstan and the Government of the Republic of Finland on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income and the Protocol to it, made in Helsinki on March 24, 2009.

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE REPUBLIC OF FINLAND

of March 24, 2009

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

Government of the Republic of Kazakhstan and Government of the Republic of Finland,

wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom 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 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 or from separate elements of the income including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

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

a) in Kazakhstan:

(i) corporate income tax;

(ii) individual income tax;

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

b) in Finland:

(i) national income taxes;

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