AGREEMENT BETWEEN THE REPUBLIC OF TAJIKISTAN AND UKRAINE

of September 7, 2002

About avoidance of double taxation and prevention of tax avoidance on the income and the capital

The Republic of Tajikistan and Ukraine, being guided by the aspiration to develop and strengthen economic, scientific and technical and cultural cooperation between both states and for the purpose of avoidance of double taxation and prevention of tax avoidance on the income and the capital, decided to sign this agreement and agreed as follows:

Article 1 of Person to which 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 the capital, the collectable Contracting State according to its legislation, 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 the total amount of the salary fund, the salary or salary paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income (profit) and the capital.

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

a) in the Republic of Tajikistan:

(I) tax on the income (profit) of legal entities;

(II) the income tax from citizens;

(III) property taxes of legal entities and physical persons; (hereinafter referred to as as "taxes of Tajikistan")

b) in Ukraine:

(I) income tax of the companies; and

(II) income tax;

(hereinafter referred to as as "taxes of Ukraine").

4. This agreement is applied also to all identical and in essence to similar taxes which will be levied in addition to the existing taxes, or instead of them, after signature date of this agreement. Competent authorities of Contracting States shall notify each other on basic changes which will be made to their corresponding tax legislations.

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