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;

(ii) corporate income tax;

(iii) utility tax;

(iv) church rate;

(v) the tax withheld at source from percent; and

(vi) the tax withheld at source from the income of nonresidents;

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

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

Article 3. General determinations

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

a) term:

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