THE CONVENTION BETWEEN THE REPUBLIC OF TAJIKISTAN AND ROMANIA

of December 6, 2007

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

The Republic of Tajikistan and Romania for the purpose of elimination of double taxation and prevention of tax avoidance on the income and the capital, decided to sign this Convention and agreed as follows:

Article 1 of Person to which the convention is applied

This Convention is applied to persons who are residents of one or both Contracting States.

Article 2 Taxes to which the convention extends

1. This Convention is applied to the taxes on the income and the capital levied according to the legislation of one of its Contracting states administratively - territorial subdivisions or regional authorities, irrespective of method of their collection.

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

3. In particular, treat the taxes operating now to which extends operations of the Convention:

a) in Tajikistan:

(i) income tax of legal entities;

(i) the income tax from physical persons;

(iii) property tax of legal entities and physical persons;

(further mentioned as "tax of Tajikistan").

b) in Romania:

(i) income tax;

(i) the income tax (further mentioned as "tax of Romania").

4. This Convention is applied also to any to similar or in essence to similar taxes which will be levied after signing of this Convention 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 tax legislations.

Article 3 General determinations

1. For the purpose of this Convention if other does not follow from context:

a) the term "Contracting State" and "other Contracting State" means the Republic of Tajikistan or Romania depending on context;

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