AGREEMENT BETWEEN THE GOVERNMENT OF THE KYRGYZ REPUBLIC AND GOVERNMENT OF THE UNITED ARAB EMIRATES

of December 7, 2014

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

Government of the Kyrgyz Republic and Government of the United Arab Emirates,

wishing to develop the mutual economic and financial relations by means of the conclusion among themselves of the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income, and also to develop and strengthen economic, scientific, technical and cultural cooperation,

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, its administrative divisions or local authorities irrespective of method of their collection.

2. All taxes levied from total of income or from income elements including taxes on the income from alienation of personal and real estate, taxes on the total amount of the salary or salary paid by the companies are considered as taxes on the income.

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

a) in the Kyrgyz Republic:

- income tax;

- the income tax levied from physical persons (further referred to as as "taxes of Kyrgyzstan");

b) in the United Arab Emirates:

- corporate tax;

- the income tax (further referred to as as "taxes of the UAE").

4. This agreement is also applied to any identical or 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 will 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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