AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE REPUBLIC OF SINGAPORE

of September 19, 2006

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 the Republic of Singapore,

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

agreed about the following:

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 levied on behalf of the Contracting State or its administrative divisions, or central or 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 are considered as taxes on the income.

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

a) in Kazakhstan:

corporate income tax;

individual income tax

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

b) in Singapore:

income tax

(further referred to as as "the Singapore tax").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after the date of entry into force of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes which can happen in their legislations concerning taxes.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

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