AGREEMENT BETWEEN THE KYRGYZ REPUBLIC AND SWISS CONFEDERATION

of January 26, 2001

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

Government of the Kyrgyz Republic and Council of the Swiss Federation,

wishing to develop and strengthen economic, scientific and technical cooperation between two States, and for this purpose to sign the Agreement on avoidance of double taxation concerning taxes on the income and on the capital,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

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

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to taxes on the income and on the capital levied on behalf of one of Contracting States or its political divisions, or regional authorities irrespective of method of their collection.

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

3. The existing taxes to which the Agreement extends are in particular:

a) in Kyrgyzstan:

(1) the income tax and the income from legal entities;

(2) income tax,

(further mentioned as "the Kyrgyz tax");

b) in Switzerland:

Federal, cantonal and utility taxes:

(1) on the income (for the total amount of the income, on earned incomes, on capital revenues, on profit on production and trade on the main earnings and other income items); and

(2) on the capital (on cumulative property, personal and real estate, business assets, the paid part of share capital and reserve fund and other components of the capital),

(further mentioned as "the Swiss tax").

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