LAW OF THE REPUBLIC OF KAZAKHSTAN

of June 2, 2003 No. 421-II

About ratification of the Agreement between the Government of the Republic of Kazakhstan and the Government of People's Republic of China about avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

Ratify the Agreement between the Government of the Republic of Kazakhstan and the Government of People's Republic of China on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income made in Astana on September 12, 2001.

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA

of September 12, 2001

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

Government of the Republic of Kazakhstan and Government of People's Republic of China,

Wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

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 the taxes on the income levied on behalf of the Contracting State or its regional authorities irrespective of method of their collection.

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

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

a) in Kazakhstan:

(i) tax on the income of legal entities;

(ii) tax on the income of physical persons;

(further referred to as as "The Kazakhstan tax");

b) in China:

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