ЎзР КонунчилигиЎзР Конунчилиги/ Халқаро алоқалар/ Ўзбекистон Республикаси билан имзоланган икки томонлама шартномалар/ Давлатлар бўйича ҳужжатлар тизими/ Баҳрайн Қироллиги/ Agreement between the Government of the Republic of Uzbekistan and the Government of the Kingdom of Bahrain for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and property (Tashkent, 5th of June 2009, entried into force on 14th of October 2010)
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BETWEEN THE GOVERNMENT OF THE REPUBLIC
OF UZBEKISTAN AND THE GOVERNMENT OF THE
KINGDOM OF BAHRAIN FOR THE AVOIDANCE
OF DOUBLE TAXATION AND THE PREVENTION OF
FISCAL EVASION WITH RESPECT TO TAXES
ON INCOME AND PROPERTY
Tashkent, 5th of June 2009
Entried into force on 14th of October 2010*
The Government of the Republic of Uzbekistan and the Government of the Kingdom of Bahrain;
desiring to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Property and with a view to promoting economic co-operation between the two countries;
have agreed as follows:
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
1. This Agreement shall apply to taxes on income and on property imposed on behalf of a Contracting State or of its administrative-territorial subdivisions or local authorities, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income and on property all taxes imposed on total income, on total property or on elements of income, or of property including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on property appreciation.
3. The existing taxes to which the Agreement shall apply are in particular:
a) in Bahrain to income tax payable under Amiri Decree No. 2/1979 ("The Oil Tax");
(hereinafter referred to as "Bahrain Tax11); and
b) in the case of the Republic of Uzbekistan:
i) the tax on income (profit) of legal persons;
ii) the tax on income of individuals;
iii) the property tax;
(hereinafter referred to as "Uzbekistan tax").
4. This Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.
1. For the purposes of this Agreement, unless the context otherwise requires:
a) the term "Bahrain" means the territory of the Kingdom of Bahrain as well as the maritime areas, seabed and subsoil over which Bahrain exercises, in accordance with international law, sovereign rights and jurisdiction;
b) the term "Uzbekistan" means the Republic of Uzbekistan, and by the use in the geographical sense includes its territory, the territorial waters and air space over them where the Republic of Uzbekistan may exercise sovereign rights and jurisdiction including rights to use the subsoil and natural resources in accordance with international law and the laws of the Republic of Uzbekistan;
c) the terms "a Contracting State" and "the other Contracting State" mean the Kingdom of Bahrain or the Republic of Uzbekistan as the context requires;
d) the term "person" includes an individual, a company and any other body of persons;
e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes or any other entity constituted or recognized under the laws of one or other of the Contracting States as a body corporate;
f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
g) the term "international traffic" means any transport by a ship, aircraft, railway or road vehicle operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
h) the term "competent authority" means:
i) in the case of Bahrain the Minister of Finance or his authorized representative; and
ii) in the case of Uzbekistan the State Tax Committee or its authorized representative;
i) the term "national" means:
i) any individual possessing the nationality of a Contracting State;
ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State;
j) the term "tax" means any tax covered by Article 2 of this Agreement.
2. As regards the application of this Agreement by a Contracting State any term not therein defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State concerning the taxes to which the Agreement applies. The meaning of a term under the taxation law of that State shall...