AGREEMENT

of February 9, 1994

About avoidance of double taxation of the income between the Republic of Turkey and the Azerbaijan Republic

Aiming to avoid cases of double taxation of the income and to sign the agreement encouraging economic cooperation between both countries, the government of the Republic of Turkey and the government of the Azerbaijan Republic came to the arrangement as follows:

Article 1. Persons to whom the Agreement is applied

1. This agreement is applied to persons which are residents of one of Contracting States or both Contracting States.

Article 2. Types of tax to which operation of the Agreement extends

1. This agreement is applied to the taxes levied from the income in the Contracting State, its territorial and administrative zones or regional authorities irrespective of procedure for their collection.

2. Irrespective of procedure for their collection, all taxes withheld from the total amount of the income or their separate elements including tax on the income from alienation of personal or real estate, taxes levied from the total amount of salary and benefits issued by the companies and taxes on income gained from property value increment are considered as taxes on the income.

3. This agreement extends, generally to the following operating taxes:

a) in the Republic of Turkey:

1) tax on the income;

2) structural tax;

3) the share share levied from tax on the income and structural tax (further hereinafter are referred to as as "The Turkish tax");

b) the taxes operating in the legislation of the Azerbaijan Republic:

1) taxes on profit and separate income types of legal entities;

2) tax on the income levied from physical persons (further hereinafter are referred to as as "The Azerbaijani tax").

4. This agreement after signing will be applied to the taxes on the income levied in addition to the operating taxes or instead of them equal or similar to the operating taxes. Authorities of Contracting states shall inform each other for the purpose of application of this agreement essential changes in the tax legislations.

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