AGREEMENT BETWEEN THE GOVERNMENT OF THE KYRGYZ REPUBLIC AND GOVERNMENT OF THE REPUBLIC OF POLAND

of November 19, 1998

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

The government of the Kyrgyz Republic and the Government of the Republic of Poland, being guided by the aspiration to develop and strengthen economic, scientific and technical and cultural cooperation between both States and for the purpose of elimination of double taxation of the income and the capital, decided to sign this agreement, and 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 and the capital levied according to the legislation of everyone of their Contracting States irrespective of method of their collection.

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

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

a) in the Kyrgyz Republic:

i) the income tax and the income from legal entities;

ii) the income tax from physical persons,

(further the referred to as "Kyrgyz taxes");

b) in the Republic of Poland:

i) the income tax from legal entities;

ii) the income tax from physical persons,

(further the referred to as "Polish taxes").

4. This agreement is also applied to any identical and 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.

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