AGREEMENT BETWEEN THE KYRGYZ REPUBLIC AND REPUBLIC OF FINLAND

of April 3, 2003

About avoidance of double taxation concerning taxes on the income

The government of the Kyrgyz Republic and the Government of the Republic of Finland Wishing to sign the Agreement on avoidance of double taxation in the relation

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 taxes levied from total of income or on separate elements of the income, including taxes on the income from alienation of personal and real estate, and also taxes levied from the income from capital gain are considered as taxes on the income.

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

a) in Kyrgyzstan:

1) income tax and income of legal entities; and

2) the income tax from physical persons;

(further referred to as as "Kyrgyzstan taxes");

b) in Finland:

1) national income taxes;

2) corporate income tax;

3) utility tax;

4) church rate;

5) the tax on percent levied at source; and

6) the tax on the income of nonresidents levied at source; (further the referred to as "Finnish taxes").

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 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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