Convention between the republic of Kazakhstan and the republic of Latvia For the avoidance of double taxation and the рrevention of fiscal evasion with resрect to taxes on income and on capital (Astana, 06/09/2002)

Convention between the republic of Kazakhstan and the republic of Latvia
For the avoidance of double taxation and the prevention of fiscal evasion
with respect to taxes on income and on capital
(Astana, 06/09/2002)

See: Protokol to this Convention

The Republic of Kazakhstan and the Republic of Latvia,

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

Have agreed as follows:

Article 1 Personal scope

This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article 2 Taxes covered

1. This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its local authorities, irrespective of the manner in which they are levied.

2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.

3. The existing taxes to which the Convention shall apply are in particular: a) in Kazakhstan:

(i) the tax on income of legal persons and individuals;

(ii) the tax on the property of legal persons and individuals; (hereinafter referred to as "Kazakhstan tax");

b) in Latvia:

(i) the enterprise income tax (uznemumu ienakuma nodoklis);

(ii) the personal income tax (iedzivotaju ienakuma nodoklis);

(iii) the property tax (ipasuma nodoklis);

(hereinafter referred to as "Latvian tax")

4. The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.

Article 3 General definitions

1. For the purposes of this Convention, unless the context otherwise requires:

a) the terms "a Contracting State" and "the other Contracting State" mean Kazakhstan or Latvia, as the context requires;

b) the term:

(i) "Kazakhstan" means the Republic of Kazakhstan. When used in a geographical sense, the term "Kazakhstan" includes the territorial waters, and also the exclusive economic zone and continental shelf in which Kazakhstan, for certain purposes, may exercise sovereign rights and jurisdiction in accordance with international law and in which the laws relating to Kazakhstan tax are applicable;