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)

Функция недоступна

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*

See the text of the document

in the Uzbek language

Article 1. Personal scope

Article 2. Taxes covered

Article 3. General definitions

Article 4. Resident

Article 5. Permanent establishment

Article 6. Income from immovable property

Article 7. Business profits

Article 8. International transport

Article 9. Associated enterprises

Article 10. Dividends

Article 11. Income from Debt-Claims

Article 12. Royalties

Article 13. Property gains

Article 14. Independent personal services

Article 15. Dependent personal services

Article 16. Directors' fees

Article 17. Artistes and sportsmen

Article 18. Pensions

Article 19. Government service

Article 20. Students

Article 21. Other income

Article 22. Property

Article 23. Elimination of double taxation

Article 24. Non-discrimination

Article 25. Mutual agreement procedure

Article 26. Limitation on benefits

Article 27. Exchange of information

Article 28. Members of diplomatic missions

and consular posts

Article 29. Entry into force

Article 30. Termination

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:

Article 1. Personal scope

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

Article 2. Taxes covered

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.

Article 3. General definitions

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 have priority over the meaning provided for such term in other branches of law of that State.

Article 4. Resident

1. For the purposes of this Agreement, the term "resident of a Contracting State" means:

a) in the case of Bahrain, its local authorities and any person who under the laws of Bahrain is domiciled or resident in, a citizen of, or having their place of incorporation or management within