On the ratification of the Multilateral Convention on the Implementation of Measures Related to Tax Agreements in order to counteract the erosion of the tax base and the withdrawal of profits from taxation

The Law of the Republic of Kazakhstan dated February 20, 2020 No. 304-VI SAM.

      To ratify the Multilateral Convention on the Implementation of Measures Related to Tax Agreements in order to Counteract the Erosion of the Tax Base and the Withdrawal of Profits from Taxation (hereinafter referred to as the Multilateral Convention), signed in Paris on November 24, 2016, with the following reservations and declarations:

      1. The Republic of Kazakhstan declares that, in accordance with paragraph 1 of Article 28 of the Multilateral Convention, it reserves the right not to fully apply articles 3, 5 and 11 of the Multilateral Convention to all bilateral international agreements for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income concluded by the Republic of Kazakhstan with foreign States.

      2. According to paragraph 1 of Article 29 of the Multilateral Convention:

      1) The Republic of Kazakhstan declares that, in accordance with paragraph 4 of Article 4 of the Multilateral Convention, the following bilateral international agreements for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income concluded by the Republic of Kazakhstan with foreign States contain the provision set out in paragraph 2 of Article 4 of the Multilateral Convention, which is not the subject of a reservation in in accordance with subparagraphs (b) – (d) of paragraph 3 of Article 4 of the Multilateral Convention:

       2) Республика Казахстан заявляет, что в соответствии с пунктом 5 статьи 6 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, не являются предметом оговорки в соответствии с пунктом 4 статьи 6 Многосторонней конвенции и указанные ниже формулировки их преамбул, за исключением заключенных в угловые скобки, подлежат изменениям в соответствии с пунктом 2 статьи 6 Многосторонней конвенции: 

       3) Республика Казахстан заявляет, что в соответствии с подпунктом с) пункта 17 статьи 7 Многосторонней конвенции применяет Упрощенное положение об ограничении льгот в соответствии с пунктом 6 статьи 7 Многосторонней конвенции ко всем двусторонним международным соглашениям об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенным Республикой Казахстан с иностранными государствами; 

       4) Республика Казахстан заявляет, что в соответствии с подпунктом а) пункта 17 статьи 7 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, не являются предметом оговорки в соответствии с подпунктом b) пункта 15 статьи 7 Многосторонней конвенции и содержат положения, изложенные в пункте 2 статьи 7 Многосторонней конвенции: 

       5) Республика Казахстан заявляет, что в соответствии с подпунктом с) пункта 17 статьи 7 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положения, изложенные в пункте 14 статьи 7 Многосторонней конвенции: 

       6) Республика Казахстан заявляет, что в соответствии с пунктом 4 статьи 8 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положения, изложенные в пункте 1 статьи 8 Многосторонней конвенции, которые не являются предметом оговорки в соответствии с подпунктом b) пункта 3 статьи 8 Многосторонней конвенции: 

       7) Республика Казахстан заявляет, что в соответствии с пунктом 8 статьи 9 Многосторонней конвенции применяет пункт 4 статьи 9 Многосторонней конвенции ко всем двусторонним международным соглашениям об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенным Республикой Казахстан с иностранными государствами; 

       8) Республика Казахстан заявляет, что в соответствии с пунктом 7 статьи 9 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, изложенное в пункте 1 статьи 9 Многосторонней конвенции: 

       9) Республика Казахстан заявляет, что в соответствии с пунктом 5 статьи 12 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, изложенное в подпункте а) пункта 3 статьи 12 Многосторонней конвенции: 

       10) Республика Казахстан заявляет, что в соответствии с пунктом 6 статьи 12 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, изложенное в подпункте b) пункта 3 статьи 12 Многосторонней конвенции: 

       11) Республика Казахстан в соответствии с пунктом 7 статьи 13 Многосторонней конвенции выбирает вариант А в соответствии с пунктом 1 статьи 13 Многосторонней конвенции; 

       12) Республика Казахстан заявляет, что в соответствии с пунктом 7 статьи 13 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, изложенное в подпункте а) пункта 5 статьи 13 Многосторонней конвенции: 

       13) Республика Казахстан заявляет, что в соответствии с частью i) подпункта b) пункта 6 статьи 16 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, предусматривающее, что заявление, о котором говорится в первом предложении пункта 1 статьи 16 Многосторонней конвенции, должно быть представлено в течение определенного периода времени, составляющего менее чем три года с момента первого уведомления о действии, приводящем к налогообложению не в соответствии с положениями двусторонних международных договоров об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенных Республикой Казахстан с иностранными государствами: 

       14) Республика Казахстан заявляет, что в соответствии с частью ii) подпункта b) пункта 6 статьи 16 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, предусматривающее, что заявление, о котором говорится в первом предложении пункта 1 статьи 16 Многосторонней конвенции, должно быть представлено в течение определенного периода времени, составляющего не менее трех лет с момента первого уведомления о действии, приводящем к налогообложению не в соответствии с положениями двусторонних международных договоров об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенных Республикой Казахстан с иностранными государствами: 

       15) Республика Казахстан заявляет, что в соответствии с частью ii) подпункта с) пункта 6 статьи 16 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, не содержат положение, указанное в части ii) подпункта b) пункта 4 статьи 16 Многосторонней конвенции: 

       16) Республика Казахстан заявляет, что в соответствии с частью i) подпункта d) пункта 6 статьи 16 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, не содержат положение, указанное в части i) подпункта c) пункта 4 статьи 16 Многосторонней конвенции: 

       17) Республика Казахстан заявляет, что в соответствии с частью ii) подпункта d) пункта 6 статьи 16 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, не содержат положение, указанное в части ii) подпункта c) пункта 4 статьи 16 Многосторонней конвенции: 

       18) Республика Казахстан заявляет, что в соответствии с пунктом 4 статьи 17 Многосторонней конвенции следующие двусторонние международные соглашения об избежании двойного налогообложения и предотвращении уклонения от налогообложения в отношении налогов на доход, заключенные Республикой Казахстан с иностранными государствами, содержат положение, изложенное в пункте 2 статьи 17 Многосторонней конвенции:  

Neophytic transition  

The Republic of Kazakhstan  

The multi-tasking Convention on the issue of measures, related to tax considerations, in order to regulate the tax base and issue of tax blocking  

      June 25, 2018 in Astana, Kazakhstan, Mr. Bakyt Sultanov, Minister of Finance of the Republic of Kazakhstan, all representatives of his government, signed:  

      The multiethnic Convention on measures, related to tax considerations, in order to regulate the tax base and exit from the tax code, improved in Paris on November 24, 2016.  

     According to the Articles 28(7) and 29 (4) of the convocation of the Republic of Kazakhstan, a preliminary report was submitted after the signing of the relevant agreements and agreements.

      The protocol was signed and signed by Mr. Jose Fecteau (Josee Fecteau), deputy director on the right issues, in two branches, one of which will be signed in the archives of the OECD, another step in the Republic of Kazakhstan.  

      Deputy director on legal issues Jose Fecteau (Josee Fecteau)  

     I confirm that the text of the protocol of the signing of the Multilateral Convention on the implementation of measures related to tax agreements in order to combat masking of the tax base and withdrawal of profits from the sphere of taxation in the Kazakh language corresponds to the text in the original language.

     Head of the document editing and Linguistics Examination Department of the Document Management Department of the Ministry of Finance of the Republic of Kazakhstan

B. M. Akhmetzhanova

      Neophytic transition  

The multi-tasking Convention on the issue of measures, related to tax considerations, in order to regulate the tax base and issue of tax blocking  

      The storylines of the current convention,  

      it should be noted that the government does not have significant budget expenditures in part of the tax on the organization's aggressive international tax planning, as a result of which it is located on the territory, where it is not subject to the tax or is not subject to a fixed rate;  

     taking into account the introduction of the tax base and the exit from the tax code (BEPS), there is an actual problem not only for the developed country, but also for the formed economy and developing country;

      taking into account the importance of ensuring total, the main economic activity of the region was discussed, as a result of which it will be formed and created cost;  

      supporting the Mer package, developed in accordance with the OECD plan/"groups of two countries" for BEPS (further-OECD / G20 plan BEPS);  

     The response is that the OECD/G20 BEPS Plan has added measures related to tax agreements to address the application of hybrid tax award schemes, providing for the operation of the requirements of the agreements, addressing the issue of artificially excluding permanent representation statuses and improving dispute resolution procedures;

      the need to ensure high-speed, coordinated and coordinated implementation of multi-level measures of BEPS, connected with negative agreements;  

      in addition, the urgent need to ensure that the relevant agreements on the elimination of double taxation on the income of nalogas were reached in order to ensure the protection of double taxation in respect of nalogas, which are distributed according to these agreements, or not created opportunities for non-payment or non-payment of payments to non-payment of taxes (including through the use of residents of third jurisdictions of pre-payment agreements, National Payments for payment of taxes, pre-payment agreements);  

      the need for effective mechanism of introduction of related changes coordinated and rational assistance in the direction of all relevant agreements on the elimination of double taxation on taxes without the need to carry out bilateral negotiations every step of the way;  

     the bottom was covered with:

PART I. SPHERE OF ACTIVITY AND POPULARIZATION OF TERMS

Article 1-sphere of activity Convention

     The current convention changes all negative agreements, which are published by the current convention, according to the subparagraph A) of Paragraph 1 of Article 2 "Tolkening of terms".

Article 2-Tolkovanie terminov

     1. in order to meet the following ponyatia:

     a) The Term "Tax Agreement, which is announced by the current convention" describes the agreement on the elimination of double tax blocking in the direction of taxes at the end (in addition, it is announced by other taxes):

     i) which acts in the direction of two or more:

     A) Storon; and / or

     C) jurisdiction or territory, where there are conversations of expressed agreement and for the sake of international relations, there is a responsible conversation; and

     ii) in respect of which each Depository has been added to its documents or applications (with reference to the name, the story, the date of entry and entry, if this is the moment of completion, the date of entry in the silhouette) according to him, the current meeting is being held.

     b) the term "Storona" is pronounced:

     i) the state, in respect of which the current convention has entered into force in accordance with Article 34; or

     ii) jurisdiction, which was signed by the corresponding Convention in accordance with the subparagraph B) or C) at Point 1 of Article 27 (entry and ratification, adoption or settlement), and for which the corresponding Convention was placed in accordance with Article 34 (entry in accordance with the subparagraph).

     C) the term "determining jurisdiction" describes the story of a negative agreement, which is published by the existing Convention.

     d) the term "entering into a conversation" speaks of the state or jurisdiction, which entered into a convention, but not entered into another convention.

     2. at the beginning of a conversation about the current convention in a good time, not determined in what, if from the context does not appear in any way, it has the meaning that the current convention.

PART II.HYBRID SCHEMES FOR THE REDUCTION OF TAX CREDITS

Article 3-fiscal-prosaic persons

     1. in order to implement tax legislation, which is distributed by the current convention, the court, the person who received it, or through it, or with the help of structures, which are considered complete or partially transparent with the amount of tax legislation, is obliged to comply with tax legislation love is considered in the quality of the residence of the dogmatic jurisdiction, but only in part, in this case, the residence of the dogmatic one is considered to be the residence of the dogmatic one for the reasons of the blocking in this dogmatic one jurisdiction.

     2. The law on Tax Compliance, which is published by the current convention, which determines the jurisdiction of the court from tax blocking or provision of a fee for the amount of tax, paid in the court, received by a resident of the court, which determines the amount of tax, which determines the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax, the amount of tax. jurisdiction, which can be related to other determining jurisdiction on the basis of the law, which is published by the current convention, which does not apply to the wedding, in this regard, there is an opportunity to establish links in this other relevant jurisdiction, only on the basis of which the income is also received by a resident of this other relevant jurisdiction.

     3. in respect of negative opinions, which are published at the current convention, in respect of which one or another story was made of fire, destroyed in Lieutenant Colonel a) in point 3 of Article 11 (the introduction of negative opinions in the direction of respect of stories in "the next proposal will be included in the meeting point 1:" "in addition to the meeting at the same point, it is not necessary to consider how the law on determining the jurisdiction of the residents of this country should be applied"". "determining jurisdiction".

     4. Point 1 (with reference to changes, which can be made at Point 3) is applied either to the receipt of tax payments, which are announced at the current convention, in the wedding, in the first place, received through persons or structures, which are considered according to the public law, according to the detailed determination of specific forms and types of persons or structures, the residence is located at the residence.determining jurisdiction.

     5. A party may reserve its right:

     (a) Not to accept the full text of this article with respect to their Tax Agreements to which this Convention applies;

     (b) Not to apply paragraphs 1 to their Tax Agreements to which this Convention applies, which are already contained in the provisions amended in paragraph 4;

     c) do not apply to point 1 in respect of their tax payments, which are distributed at the current convention, which are related to payments, fixed at point 4, which are provided for payment in respect of payments, received by the person or through them, or with supporting structures, which are located in the third jurisdiction;

     d) do not take into account Point 1 in relation to their negative opinions, which are published by the current convention, which are regulated by law, in point 4, which detail determines specific forms and types of such persons or structures;

e) do not take Point 1 in relation to their tax obligations, which are distributed to the current convention, which have the right to change, which is regulated in point 4, which detail determines concrete forms and types of such persons or structures, and which determine in the provision of Lig according to the agreement in the field, the received person or through it, or with the help of structures, which are located in the third jurisdiction;

     f) do not take Point 2 in relation to their negative opinions, which are published by the current convention;

     g) take Point 1 only in relation to their negative opinions, which are published by the current convention, which are regulated by law, and in point 4, which are detailed concrete forms and types of such persons or structures.

     6. every story, which did not contain the incident according to the Lieutenant Colonel A) or b) at point 5, the volume of depositions is increased, which is related to some negative conclusion, which is published at Point 4, which is not provided for by the incident in point 4, which is not provided by the incident in point 5, which is not provided by the incident in point 5, which is not provided by the incident in point 5, which is not provided by the incident in point 4, which is not provided by the incident in point 5, which is not provided by the incident in point 4, which is not provided by the incident in point 5, which is not provided by the incident in point 4, which is not provided by the incident in point 5, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point 4, which is not provided by the incident in point according to the subunits with C) to e) point 5, and if so, apply the number of articles and the number of such items at the point. In the case of the report, which was submitted to the head of the department G) at point 5, the proposal is submitted according to negative opinions, which are published by the current convention, in respect of which the head of the head of the department is a member of the board of directors of the company G) at point 5, the provision is made according to the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5, the proposal of the head of the company G) at point 5. If all relevant jurisdictions have agreed on such tax agreements, which are announced by the current convention, these agreements are imposed on points 1 (with changes, which can be established at Point 3) in the wedding stepeni, as it was proposed by Point 4. In a negative speech, Point 1 (with the changes made, which can be made at Point 3) imposes its own tax agreement, which is announced at the current convention, only in the wedding step, in which the changes are not made at Point 1 (with the changes made, which are made at Point 1) you can be saved at Point 3).

 Article 4-persons with dual residency

     1. If according to the laws of the Republic of Kazakhstan, which are published by the current convention, the person, Foreign and physical, is a resident of more than one relevant jurisdiction, the Competent Authority of the relevant jurisdiction will be stressed according to the relevant jurisdiction, the resident believes that such persons for tax purposes are distributed by the current convention, studying the distribution of his place of factual management, his place of Incorporation or a love analogous place of his place of study, as well as other knowledge factors. According to this agreement, this person does not presuppose the existence of Libs or the establishment of the right to trade, provided for by the current convention, if only competent authorities of the right jurisdiction will not agree what a mere and what a pity.

     2. Point 1 is taken into account or at the request of a tax agreement, which is published by the current convention, which establishes the right of a person, not a physical person, a resident of the same jurisdiction in servants, when such a person in a negative opinion, we should consider a resident with more than one jurisdiction. The same point 1 does not apply to tax payments, which are announced by the current convention, which deals with the resolution of the resident company, participating in the agreements on the creation of a dual-listed company (dual-listed company arrangements).

     3. The Story can remain true:

     a) do not take full responsibility for their negative opinions, which are published by the current convention;

     b) do not take full responsibility for their negative opinions in relation to the current convention, which is distributed by the current convention, which includes people, persons, Foreign and physical persons, who are more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person jurisdiction, and reaching mutual agreement of competent authorities on the establishment of such a person as a resident of one of the determining jurisdictions;

     c) do not take full responsibility for their negative opinions in relation to the current convention, which is based on the provisions of the convention, which includes citizens, persons, Foreign and physical persons, who are more than one person, who are more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person jurisdiction, and it is necessary to ensure the right to agree without trebovaniya achievement of mutual agreement of competent authorities on the provision of such persons as residents of one and the same guessing jurisdiction;

     d) do not take full responsibility for their negative opinions in relation to the current convention, which is based on the provisions of the convention, which includes citizens, persons, Foreign and physical persons, who are more than one person, who are more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, who is more than one person, jurisdiction, and the achievement of mutual agreement of competent authorities on the establishment of such a person as a resident of the same jurisdiction, and they have the right to impose a tax agreement on it the current convention on the treatment of such persons, if so, it can be achieved;

     (e) Replace the last sentence of paragraph 1, for the purposes of their Tax Agreements to which this Convention applies, with the following text: "When considering such an agreement, this person shall not be granted any benefits or tax exemptions provided for by a Tax Agreement to which this Convention applies.";

     f) do not take full responsibility for the current status in respect of their negative opinions, which are published by the current convention, according to reports, which were sent to the lieutenant colonel e).

     4. every story, which did not come to the conclusion according to the Lieutenant Colonel A) at Point 3, it is necessary to increase the volume of deposits, which includes some from it taxable amounts, which are distributed to the current convention, which is canceled at point 2, which does not apply to the proposal lights in accordance with sub-divisions with B) to D) at Point 3, and in the case of delivery to the number of items and at the point of each such payment. If all the relevant jurisdictions have agreed on the provision in respect of tax claims, which are published by the current convention, such claims are imposed on points 1. in a negative case, Point 1 imposes such claims on tax claims, which are the current convention is announced only in the event of a wedding, in which these changes are not made with Point 1.

Article 5-introduction of methods of double taxation

     1.The Story can specify libo points 2 and 3 (option a), libo points 4 and 5 (Option B), libo points 6 and 7 (Option C), libo can not specify one of the options. If any guessing jurisdiction, which is published by the current convention, issues different variants (or if one guessing jurisdiction issues a variant, another does not issue one of the variants), to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to variant, to Variant every lawful jurisdiction is imposed on residents.

      Variant A

     2. There is a negative agreement, which is approved by the current convention, which in the negative case is determined by the received income or capital, which has a resident's right to choose a jurisdiction, from the right to choose a jurisdiction in accordance with the terms of the two-way agreement nalogoblozheniya, which is not accepted, if other relevant jurisdiction at the request of the tax agreement, which is published by the current convention, determines such a profit or capital from nalogoblozheniya or imposes a pondered bet on the nalog, according to this date, or capital can be extended. In the following speech, the first comprehensive guessing jurisdiction provides for the sale or capital of such a residence in the size, the same as the previous one, determined in this other guessing jurisdiction. One way or another, it is not necessary to exclude the amount of tax, which is considered to provide access to such views of the land and capital, which can be transferred to other tax authorities.

     3.point 2 is applied in relation to the Tax Agreement, which is published by the current convention, according to which the law of the Republic of Kazakhstan is determined by the jurisdiction to determine the amount or capital, as defined in this point.

      Option B

     4. According to the current convention, the received income of the residence is determined by the law of the Republic of Kazakhstan on tax evasion in this law of the Republic of Kazakhstan with the purpose of obtaining double tax evasion in accordance with the law of the Republic of Kazakhstan "on tax evasion in the Republic of Kazakhstan". the basis of this agreement is considered in this determining jurisdiction in terms of dividends, not to mention, if such a conclusion is made for those who decide on a tax-free residence in another determining jurisdiction in accordance with the law of the Republic of Kazakhstan. with the law it is another determining jurisdiction. In this regard, the first comprehensive identifying jurisdiction provides for a tax on the income of such a residence in the size, the same tax on the income, paid in this other identifying jurisdiction. One way or another, it is not necessary to exclude the amount of tax at the end of the year, considered to provide an exit from such an end, which can be attributed to other identifying jurisdictions.

5.Point 4 is applied in relation to the Tax Agreement, which is published by the current convention, according to which the law of the Republic of Kazakhstan is determined by the law of the Republic of Kazakhstan, approved in this point.

      Option S

     6. A) if a resident of a determining jurisdiction receives income or owns Capital, which can be attributed to another determining jurisdiction in accordance with the criteria of a negative opinion, which is published by the current convention (for the exclusion of technology according to the head of the department, such measures will allow us to establish a link in this other identifying jurisdiction only to the extent of its significance, which is also the residence of this other identifying jurisdiction), first of all, determining the identity of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person who is responsible for the registration of the person jurisdiction presupposes:

     i) a tax on the income of this residence in the size, a tax on the income, paid in this other determining jurisdiction;

     (II) the tax on capital in the size of this residence, the tax on capital, determined in this other determining jurisdiction.

     This exit, one way or another, does not have to prevent part of the tax on income or capital, as it was proposed to move to income or capital, which can be attributed to this other determining jurisdiction.

     b) if in accordance with the requirements of the tax law, which is approved by the current convention, the income received by the resident of the relevant jurisdiction, or the capital received by the authorized capital, is determined by the tax code in this relevant jurisdiction, such a determining jurisdiction can, however, not only increase the amount of tax for the remaining part of the income or capital of such a residence, but also increase the amount of tax from the income or capital.

     7. point 6 is set to include tax compliance, which is announced by the current convention, according to which in order to establish a two-way tax blocking, the jurisdiction must determine from the tax in this tax-related jurisdiction, a resident who has received this right of jurisdiction, or has received the capital, which in accordance with the laws of the Republic of Kazakhstan, is declared by the current convention, can apply to other right of jurisdiction.

     8.The Story, which did not come out of one of the options according to point 1, can be left for the sake of full non-fulfillment of this article in one or other non-specified tax agreements, which are published by the current convention (or in respect of all according to the current convention).

     9. The Story, which did not come up for an option with, can be left for the same law in respect of one or other illegal agreements, which are published by the current convention (or in respect of all those negative agreements, which are the convention), which does not define another jurisdiction (other jurisdictions), should take the option with.

     10.every story, which draws up a variant according to the point 1, carries out Depository on your option. Such improvement also includes:

     A) in the speech, if there is an option A, all tax agreements, which are published at the current convention, which are signed at Point 3, as well as the number of articles and points of each such agreement;

     b) in this case, if the story is issued by Option B, all tax agreements, which are published at the current convention, which are signed at point 5, as well as at the number of articles and points of each such agreement;

     c) in the case of a question, there is a variant of C, all related agreements, which are announced at the current convention, which are signed at Point 7, as well as at the number of articles and points.

     The option is applied in respect of the tax agreement, which is published by the current convention, only if the question arises of this option, it has been resolved in respect of this agreement.

 PART III.HARMFULNESS OF CLAIMS

 Article 6-celibacy, which is announced by the current convention

     1. a negative agreement on which the current convention will be amended in order to include in the preamble the text of the following agreement:

     "It is necessary to maintain double taxation in respect of taxes, for which there is no agreement, not to create an opportunity for non-taxable or pondered taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable taxable"the use of residents of third jurisdictions of pre-existing agreements, National Payments for profit, provided for such agreements),""."

     2. the text, entered at Point 1, is included in the Tax Agreement, which is published by the current convention, or at the request of the preamble of the formulas of the Tax Agreement, which is published by the current convention, which is issued by the name of the two-way agreement non-binding, not necessarily from above, is introduced or not introduced in such a formula as to create an opportunity for non-binding or non-binding.

     3. The Story can also be decided on the inclusion of the following preamble text in the address of their negative opinions, which are published by the current convention, which does not contain the preamble formula, which is intended to develop economic relations or strengthen it Cooperation in tax activities:

     "It is necessary to further develop their economic relations and strengthen cooperation in tax activities."

     4. According to the law, it is not necessary to take into account the point 1 of its negative opinions, which are published by the current convention, which includes the formulation of the preamble of the preamble of the relevant jurisdiction, not to apply for a double tax deduction, not to create opportunities for non-payment or non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment, non-payment preconceived prejudice, at the same time, the convention is being ratified) or it is intended to be adopted more closely.

     5. every story is based on the volume of deposits, which are subject to certain agreements, which are published by the current convention, i.e. technologies, which are provided for by the rules in accordance with Point 4, the preamble of the formula, specified in point 2, and IFLI the text of the corresponding preamble. If all the relevant jurisdictions have agreed to such an agreement in respect of this preamble formula, the preamble formula is written in point 1. In other reports, the text, written at Point 1, is added to the current preamble formula.

     6.every time the decision is made on the appointment of Point 3, The Depositary will be transferred to your account. Such approval also includes the words of the tax agreements, which are published at the current convention, which do not contain the preamble to formulate the provisions of the agreement to develop economic relations or strengthen cooperation in tax matters. The text, stated in point 3, is included in the Tax Agreement, which is published by the current convention, only if all the relevant jurisdictions have adopted a resolution on the issue of this point and have also adopted such a resolution in the tax agreement, which the current convention is announced.

Article 7-presupposition of harmfulness of claims

     1. It is impossible from the love of the Tax Agreement, which is announced by the current convention, which is announced by the current convention, which is not provided for in the way of income or capital, if, taking into account the introduction all relevant facts and conditions are based on the fact that obtaining such Lig was one of the main targets of such Lig agreement or agreements, which were directly or jointly acquired for this Lig, if only it was not established, the provision of such benefits in these conditions will correspond to the goals and objectives of the corresponding agreements, which are announced by the current convention.

     2. Point 1 is applied either by submission to the Tax Agreement, which is published by the current convention, the terms, which say in submission to all or part of the law, which were provided in compliance with the tax code according to the current convention, if the main or one of the main objectives of the agreement or agreement, or the person related to the agreement or agreement, received such income.

     3. A Party that has not made the reservation referred to in subparagraph (a) of paragraph 15 may also decide to apply paragraph 4 in respect of its Tax Agreements to which this Convention applies.

4. If a person said in advance that the current convention is being distributed, the basis of the current tax agreement, the current convention is being distributed (with reference to changes, which may be established by the current convention). convention), which are expressed in the provision of all or part of Labor, which were provided in accordance with the Tax Agreement, which is announced at the current convention, if the main or one of the main targets of love agreement or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or one of the main goals of the convention, or "I don't know," she said., related to the agreement or agreement, this is the acquisition of such Lig, a competent body that determines the jurisdiction, which in the negative case provided for this Lig, but I do not consider that such people have the right to such Lig or other Lig in referring to the concrete source of income or capital, if such a competent authority to address such persons and after taking into account relevant facts and facts, it is established that such interests were provided to those who received income or income. The Competent Authority of the relevant jurisdiction, which in accordance with the relevant point was directed to the resident of another relevant jurisdiction, will consult with the Competent Authority of another relevant jurisdiction.

     5. Point 4 is applied to tax payments, which are distributed by the current convention (with the rules, which can be established by the current convention), which are issued in order to provide all or part of the income, which are in a negative meeting provided in accordance with the Tax Agreement, which is announced at the current convention, if the main or one of the main targets of love agreement or agreement or any other person, related to agreement or agreement, received such income.

     6. It is also possible to adopt a decision on the application of their tax obligations, which are distributed at the same points from 8 to 13 (in addition, "increased payment of income"), which is approved in accordance with the legislation of the Republic of Kazakhstan Lieutenant Colonel C) at point 17. an extended list of violations of the law is submitted in respect of tax claims, which are published by the current convention, only if all relevant jurisdictions have adopted a resolution on its application.

     7. in cases where there are certain, but not all related jurisdictions, which are distributed by the current convention, a decision has been made on the adoption of approved measures to reduce the burden on the population in accordance with Point 6, which is impossible from the point of view of the law at the same point, an improved measure of compliance with the law is applied in relation to the provision of compliance with the law, which is announced by the current convention:

     (a) All Contracting Jurisdictions, if all Contracting Jurisdictions that have not decided to apply the Enhanced Provision in accordance with paragraph 6 agree to such application by selecting the application of this subparagraph and clarifying the relevant provision in images; or

     b) only in the guessing jurisdiction, which have been removed from the application of the enhanced application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of the application of The according to the same principle, the issue of the current lieutenant colonel and the corresponding image of the depositary is resolved.

      Increased blood pressure

     8. if the foreign policy is not provided for by the law of the Republic of Kazakhstan, the resident of the jurisdiction of the tax code, which is published by the current convention, will not have the right to apply to the tax code, which is provided for by the tax code of the Republic of Kazakhstan. according to the current convention, Inu, according to the law, provided for by the previous agreements, according to the current convention:

     a) those who determine the residence of a person, Foreign and physical, who are residents of more than one related jurisdiction in the field of tax law, which is published by the current convention, who determine the residence in the relevant jurisdiction;

     b) which presuppose that a certain jurisdiction presupposes a business that presupposes symmetric proofreading after first-time proofreading, based on other justifying jurisdictions in accordance with the tax code, in accordance with the legislation of the Republic of Kazakhstan, in accordance with the legislation of the Republic of Kazakhstan, in accordance with the legislation of the Republic of Kazakhstan, in accordance with the legislation of the Republic of Kazakhstan, in accordance with the legislation of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of Kazakhstan, in accordance with the law of the Republic of it is announced by the current convention, the sum of which is assigned to an Associated enterprise, which is represented in the first round of determining jurisdiction; or

     c) which will allow residents of the right jurisdiction to consider the competence of this right-wing jurisdiction, whether it is related to the right-wing jurisdiction, which is published by the current convention

     in addition, such a resident is a "Qualified Person", as it was announced at Point 9, at the moment, when the income of the population was provided.

     9. a resident of the relevant jurisdiction of the National Convention, which is distributed by a Qualified Person at the moment, when the law in a negative session was provided for by the National Convention, which is distributed by the National Convention, ifley this is the moment when a resident is born:

     a) physical face;

     b) the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of Kazakhstan, the law of the Republic of;

     c) a company or other person, if the main class of shares is regularly traded on one or other stock exchanges;

     d) a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person, a person:

     i) non-profit organization of the Republic of Kazakhstan, which has agreed with the jurisdiction over diplomatic notes; or

     ii) a person or a structural, created in this determining jurisdiction, which is considered as a separate person in accordance with tax legislation such a determining jurisdiction and:

     A) it is created and acts as a closed or closed post for administration or provision of pension benefits, as well as additional or non-permanent benefits for physical persons, and is regulated in such a way that it is determined by the jurisdiction, one of them is political bias or local organ failure; or

     B) it is studied and acts as a closed or closed post for the investment of funds in the use of persons and structures, which are transferred to the lieutenant colonel a);

     e) a person, Foreign and physical, if in the period of the second half of the day in the 12th lunar period, which includes in Seb time, who lives in a negative session were provided, who has residents who have this jurisdiction and have according to the law on obtaining taxable income, which is distributed according to the current convention, in accordance with the points of A) to D) directly or without 50 percent of this person's shares.

     10. a) a resident who determines the jurisdiction of the Tax Court, which is published by the current convention, will have the right to apply to the Tax Court, which is published by the current convention, in respect of the income received from another determining the jurisdiction, which is not related to the qualification of a resident, if a resident is based on active entrepreneurial activity in the first round of determining the jurisdiction, and also received from other identifying persons jurisdiction, which is defined or associated with such activity. For the purposes of the Strengthened Regulation on the approval of the preferential term "ensuring active entrepreneurial activity" does not include the following types of activities or any of their content:

     i) functionality in quality of the holding company;

     ii) provision of public assistance or management of Group companies;

     (iii) Provision of group financing (inclusion of a cash facility); or

     iv) development or management of investments, if only these types of activities are not carried out by an ATM, a insurance company or a registered dealer for the price of packages during their local activities.

     b) if a resident is a resident of the relevant jurisdiction, which is published by the current convention, receives a residence permit from entrepreneurial activity, based on the title of resident in another relevant jurisdiction, or receives a residence permit, in other determining jurisdiction from a related person, provision, prescribed in lieutenant A), it is considered to be issued in such a document, if only entrepreneurial activity, which is based on a resident in the first place determining the jurisdiction to which this view is located, there is a serious attitude to analogous or complementary activities, based on the position of a resident or such a person in another relevant jurisdiction. There is a certain entrepreneurial activity for the current lieutenant colonel, which is determined on the basis of all facts and facts.

     C) for persons who are related to the residence in accordance with the relevant jurisdiction of the tax code, which is published by the current convention, is considered by such residents.

11. A resident of the jurisdiction of the Tax Court, which is published by the current convention, which is not qualified, also has the right to live, which in a negative case was provided for by the Tax Court, which is published the current Convention, on the basis of the visa regime, if the date for the next half of the day is the 12th lunar period, which includes the period of time, when people living in a negative Service were provided, who have equivalent beneficiaries, straight or straight, on Craine mere 75 percent of the share of the residence.

     12. If a resident is a resident of the jurisdiction of the tax audit, which is published by the current convention, it is not qualified by a qualified person in accordance with the requirements of points 9 and does not have rights to the rights of points 10 and 11, the Competent Authority is another expert the jurisdiction can also not provide for Lig, provided for by the current convention, or Lig in the direction of the concreteness of the court, taking into account the purpose and objectives of the tax law, which are distributed the convention, only if this resident provides for the production of such a competent body, which is the creation, creation or maintenance, which is the conduct of his operation, as one of its main objectives is to obtain profit in accordance with the tax code, which is the current convention is announced. As a result, it will be possible to consult with the Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first Resident, The Competent Authority of the first resident the law of the Republic of Kazakhstan "on the protection of rights and freedoms".

     13. for those who are satisfied with the size of the lion:

     a) the term "established foundation exchange" is recognized:

     i) love the stock exchange, the knowledge and regulation in quality of such laws of the beloved jurisdiction; and

     ii) beloved other fund exchange, trusted by competent authorities of the right of jurisdiction;

     b) the term "basic class of shares" refers to the class or class of shares of the company, which represents the majority of collective voices and the cost of the company, or class or class of participation in the company, which represents the share of the majority of collective voices and the cost of the company;

     c) the term "equivalent beneficiary" is recognized by a person who has the right to live in the land, provided for by the law of the tax jurisdiction, which is published by the current convention, in accordance with the national law it is the law that determines the jurisdiction, the tax code, which is published by the current convention, or another international document, which is analogous or more than one, which provides for the transfer of this type of visa to the country compliance with the tax code, the current convention is announced for the participants of the meeting, including those who are equivalent beneficiaries in terms of dividends, such persons are considered by the capital company, issuing dividends, which the company claims to be in favor of Return of dividends.

     d) in relation to persons, not related to companies, the term "shares" is understood as "shares, shares".

     e) two persons are considered "connected persons", if they are directly or are not owned by 50 percent of the share in other (or preferably to the company, on the contrary, only 50 percent of the share, according to the voice and representing it) or third persons either directly or by virtue of not having 50 percent of the share (or by virtue of the company, by the way, only 50 percent of the share, according to the law of the head and representing it) in every person; In any case, a person is considered to be related to another if, based on all the facts and separations related to the case, one of them controls the other or both controllers by the same person or persons.

     14. An increased percentage of income is taken into account or at the expense of tax revenues, which are distributed by the current convention, which are distributed by the current convention, which is distributed by the current convention (or by the current convention). these are related to Foreign Relations, which are related to the current convention, associated with residency, associated with enterprises or non-discrimination, or Lig, it is not limited to determining the jurisdiction of residents), only to the residence, which has the right to such conditions, corresponding to one or another criteria.

     15. the story can remain true:

     a) it is not necessary to take into account the point 1 of its negative opinions, which are published by the current Convention, on the basis of the volume, that it is necessary to take into account the content of detailed measures to reduce the burden and burden of debt, directed to the conditional financial structures, libo paid the main goal, such an image corresponds to the minimum standard for providing harm to BEPS in accordance with the BEPS plan; such students will be able to reach a comprehensive resolution that corresponds to the minimum standard;

     b) do not take Point 1 (and point 4, in this case, if the decision has been made to take this point) for its negative opinions, which are published by the current convention, which is based on the law, which says in the provision of all Lig, which in the negative meeting was presented in accordance with the tax code, which is published by the current convention, if the main or one of the main targets of love for the rights of persons, related to the rights of persons, received such rights ligot;

     c) it is not necessary to take an extended period of time to increase the burden on your tax obligations, which are announced at the current convention, which is regulated at point 14.

     16. Except in the exceptional case where an Enhanced dismissal Provision is applied to the granting of benefits under a Tax Agreement to which this Convention applies by one or more Parties in accordance with paragraph 7, the Parties that agree to paragraph 6 decide to apply the enhanced Benefits Provision may reserve the right not to apply in full. an up-to-date article in relation to their Tax Agreements, which are subject to this Convention, for those who have one or no other legal jurisdiction, a decision has not been made on the adoption of an extended settlement on the distribution of Lig. In such cases, the Contracting Jurisdictions will strive for an achievable solution that meets the minimum solution in order to ensure compliance with the requirements of the agreement in accordance with the BEPS Plan.

     17. (a) Each Party that has not made the reservation referred to in subparagraph (a) of paragraph 15 shall inform the Depositary whether each of its Tax Agreements covered by this Convention, which is not a preliminary reservation referred to in subparagraph (b) of paragraph 15, contains a provision referred to in paragraph 2, and if it contains, the number of the article and paragraph of each such provision. If all relevant jurisdictions have agreed on such an agreement, which is published by the current convention, such agreement is imposed on points 1 (i.e., where it is necessary, point 4). In other cases, point 1 (I, where it is important, point 4) is imposed on the Tax Agreement, which is announced at the current convention, only in wedding time, in such cases it is impossible to enter point 1 (I, where it is important, point 4). The meeting, which takes place in accordance with the current lieutenant colonel, can also be added to the application, on which it is necessary to take the same point at 1 in quality time measures, it is necessary to take the opportunity to change the level of income in the country at the same time, there are 1 points of double-glazed windows.

     b) every time the decision is made on the appointment at Point 4, the deposit is made on your account. Paragraph 4 applies to a Tax Agreement to which this Convention applies only if all Contracting Jurisdictions have made such a declaration.

     (c) Each Party that decides to apply the Enhanced Benefits Approval Provision in accordance with paragraph 6 shall notify the depositary of its choice. If such a Party has not made the reservation specified in subparagraph (c) of paragraph 15, such an introduction shall also include a list of its Tax Agreements to which this Convention applies, which are contained in paragraph 14, as well as the article and paragraph number of each such provision.

     d) Every Day, which does not take a decision on the receipt of payment for payment in accordance with Point 6, but takes a decision on the receipt of payment in Lieutenant Colonel A) or B) at point 7, the deposit is paid to the lieutenant colonel. If such a story did not apply to the head of the C) at point 15, this agreement also includes a number of related agreements, which are published at the current convention, which is signed at point 14, as well as the number of articles and points every so often.

E) if all the relevant jurisdiction has been approved in accordance with the sub-lieutenant C) or d) in respect of the tax agreement, which is published by the current convention, such an agreement is imposed on the increased tax burden. In other members of the extended list of income tax payments, which is announced at the current convention, only in the wedding anniversary, such payments are not made with the extended list of income tax payments.

 Article 8-operation on transfer of dividends

     1. According to the current convention, these are distributed from tax dividends, issued by companies that have resident jurisdiction, or those that determine the rate, according to which such dividends can be extended according to the minister, the person who owns the actual law on dividends, or the recipient of the company, who owns a resident of another determining jurisdiction, and who controls or decides on the law on its ownership more than the amount of Capital, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, Shares, shares, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, dividends, etc. paev, Chisla Golosov, according to the head of state or by the relevant terms of participation in the company, these payments are issued only if the provision of land, issued in such cases, was transferred in the 365th day period, which is included in the day of dividends (in order to increase this period changes are made in the structure of their property, which will be due to reorganization, liquidation, as a result of the sale or distribution of the company, holding shares or issuing dividends).

     2.the minimum period of wladeniya, provided for at Point 1, is considered to be included in or under consideration in the Tax Agreement, which is announced at the current convention, the minimum period of wladeniya, approved at point 1.

     3. The Story can remain true:

     a) do not take full responsibility for your negative opinions, which are published by the current convention;

     b) do not take full responsibility for your negative opinions, which are published by the current convention, in the wedding anniversary, in the amount of money, issued at Point 1, until the deadline:

     I) minimum period;

     ii) minimum period, which is 365 days; or

     iii) minimum period, which is more than 365 days.

     4. Every Story, which was not assigned to the head of state, not assigned to the Lieutenant Colonel A) at Point 3, contains the volume of depositions, which are related to each other, which is published by the current convention, the bill, not assigned to the head of State at point 1, which is not provided for by the head of State (B) at Point 3, and if so, the number of articles and the number of such items at the point. Point 1 is applied to the tax assessment, which is published by the current convention, only if all the relevant jurisdictions have been strengthened in relation to such a survey.

Article 9-results of payment of shares or share participation, the cost of which is represented by a pre-viable estate

     1. Approval of a tax agreement, which is approved by the current convention, presupposes that citizens who have received one-sided jurisdiction from the claim of shares or other rights of participation in the person, can apply to another tax agreement under the terms of the jurisdiction, which is more certain part of the cost of such shares or the right of undecided property, distributed in this other determining jurisdiction (or under the terms, which is more certain part property of a person is of such undemanding property (undemanding):

     a) it is assumed that if at a good time in the period of 365 days, the previous one will be treated with respect to the corresponding specific knowledge of stoicism; and

     b) shares or analog shares, such as shares in partnership or trust (in wedding anniversary, such shares or such shares are not yet approved), in addition to my favorite shares and rules, for which these shares are distributed.

     2. period, predetermined in Lieutenant Colonel A) at Point 1, it is assumed to be between or at the time of the period, which is determined by the corresponding sign, specified in point 1, in the number of negative signs, which are the current convention is announced.

     3.it is also possible to take a decision on the appointment of 4 points in respect of their negative opinions, which are published by the current convention.

     4. for the purposes of tax assessment, which is announced by the current convention, the income received by a resident of one determining jurisdiction from the payment of shares or analog shares, such as participation in partnership or trust, can be attributed to another determining the jurisdiction, if at a good time in the period of 365 days, the previous decision, the cost of such shares or similar shares is more than 50 percent of the participation directly or partially from the poor property, this is another determining jurisdiction."

     5. Point 4 is applied either at the request or at the request of the Tax Agreement, which is published by the current convention, which presupposes that a resident who has received a residence permit from the claim of shares or foreign rights to participate in the competition, can apply the tax in another determining jurisdiction, under the condition that more than one part of the value of such shares or the right of undecided property is distributed in such another determining jurisdiction, or provided that more than a certain part of the property consists of such immovable property (arrears).

     6. A party may reserve its right:

     a) do not take into account the point 1 of your negative opinions, which are published by the current convention;

     b) do not assume that A) at Point 1 of your negative opinions, which are published by the current convention;

     (c) Not to apply subparagraph (b) of paragraph 1 to their Tax Agreements to which this Convention applies;

     (d) Not apply subparagraph (a) of paragraph 1 to its Tax Agreements to which this Convention applies, which already contains a provision of the type referred to in paragraph 1, which includes a period determining whether the conditions for the relevant knowledge are met;

     (e) Not to apply subparagraph (b) of paragraph 1 to its Tax Agreements to which this Convention applies, which already contains a provision of the type referred to in paragraph 1 that applies to the alienation of equity interests other than shares;

     f) do not apply to point 4 of your negative opinions, which are published by the current convention, which are approved by point 5.

     7. Every Story, which was not sent to the head of the department A) at Point 6, contains the volume of the deposit, which is related to each of the tax payments, which is published at the current convention, the bill, approved at Point 1, and if it is sent, the number of articles and "I'm sorry," he said. Point 1 is applied in relation to the tax assessment, which is published by the current convention, only if all the relevant jurisdiction has been strengthened in relation to such a survey.

     8.every time a decision was made on the appointment of Point 4, The Depositary will be released on its own behalf. Paragraph 4 applies to a Tax Agreement to which this Convention applies only if all Contracting Jurisdictions have made such a declaration. In this regard, point 1 does not apply to this tax agreement, which is published by the current convention. In the case of cases, which were not assigned to the head of state, not assigned to the Lieutenant Colonel f) point 6 and not assigned to the head of state, not assigned to the lieutenant colonel a) point 6, this agreement includes also the words of the negative opinions, which are published by the current convention, which are signed by the head of state, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan, the president of the Republic of Kazakhstan.polozheniya, prescribed in point 5, as well as in the number of articles and points of such polozheniya. If all the relevant jurisdictions have agreed on the approval of the tax code, which is published at the current convention, the basis of which is at the current point or point 7, such a law is imposed at Point 4. In recent years, 4 points are imposed on the Tax Agreement, which is announced at the current convention, only in the wedding anniversary, in such cases it is impossible to meet with Point 4.

Article 10-it was approved to increase the number of candidates for permanent representation, repatriated in third jurisdictions

     1. Yesli:

     a) the business of determining the jurisdiction of the Tax Court, which is published by the current convention, receives the income in another determining jurisdiction and the first determining jurisdiction considers such income as Permanent Representation of enterprises, repatriated in the third jurisdiction; and

     b) in connection with such a permanent representation, it is determined from a tax in the first authorized jurisdiction,

it is expected that the current convention will not be published, according to which the tax code in the third jurisdiction contains 60 percent of the tax code, which will be taken into account first of all determining the jurisdiction with this type of jurisdiction, if such a permanent representation was extended in the first comprehensive determining jurisdiction. In this regard, there is a need to establish a tax code in accordance with the national legislation of another relevant jurisdiction, not to mention the love of other people for the tax code, in respect of which the law is applied in this point, there is a need to establish a tax code in accordance with the legislation of the Republic of Kazakhstan.this is a typical convention.

     2. Point 1 does not mean, if you are a citizen, received in other relevant jurisdiction, entered into force at Point 1, received in connection with or connected with active entrepreneurial activity, operating through permanent representation (specific from activity to development, management or simple management of investments in their own business organization, for the inclusion of technical workers, such activities are related to banking services, insurance or management of price packages, operating ATMs, insurance organizations or dealers "I don't know," he said.

     3. If you receive income, provided for by the tax code, which is published by the current convention, reported in accordance with Point 1 in the direction of the doctor's office, a resident of the same jurisdiction, a competent body of another according to the jurisdiction, it is not possible to provide such Lig in relation to such a residence, if the Competent Authority determines that such Lig is provided for by the law, which such resident does not comply with trebovania points 1 and 2. The Competent Authority of the relevant jurisdiction, which was directed by the resident of another relevant jurisdiction in accordance with the proposed proposal, will consult with the Competent Authority of this other relevant jurisdiction before submitting flattery or reprimand.

     4. points from 1 to 3 are taken into account or at the request of the relevant agreement, which is published by the current convention, which says in the provision or in violation of the law, which were provided by the enterprise one identifying jurisdiction, which receives the income in another identifying jurisdiction, which is related to the Permanent Representation of enterprises, distributed in third jurisdiction.

     5. A party may reserve its right:

     a) do not take full responsibility for your negative opinions, which are published by the current convention;

     b) do not take full responsibility for your negative opinions, which are published by the current convention, which is regulated by law, issued in point 4;

     C) apply the current status only to your negative opinions, which are published by the current convention, which are regulated by the law, issued in point 4.

     6. Every Story, which was not sent to the head of the Department, designated in point A) or b) at point 5, contains the volume of the deposit, which is related to each of the tax payments, which are published at the current convention, the date of receipt, specified in point 4, and if it is sent to the number "I don't know," he said. If all the relevant jurisdiction has been approved in respect of tax claims, which are published by the current convention, such claims are imposed on points from 1 to 3. In other cases, points from 1 to 3 are imposed on the Tax Agreement, which is announced at the current convention, only in wedding time, in such cases, without the same points.

Article 11-introduction of tax agreements in order to reduce costs in the treatment of tax evasion of their residents

     1. Tax Agreement, which is approved by the current convention, should not be applied to the tax agreement that determines the jurisdiction of its residents for the exclusion of income, which is provided in accordance with the Tax Agreement, which the current convention that:

     a) it is envisaged that the relevant jurisdiction presupposes the business of this identifying jurisdiction to be consistent or symmetrical after the first proofreading, designed for other identifying jurisdictions in compliance with the tax code it is agreed that the current convention, which is set out in the draft law, started in the first round of determining the jurisdiction of post-representation enterprises or associated enterprises;

     b) it is possible to pay attention to the blocking of this identifying jurisdiction of a physical person, as a resident of this identifying jurisdiction, if this physical person receives a payment in terms of services, related to other identifying jurisdiction, political appeal, local organs or other analog organs;

     c) it is possible to determine the degree of a physical person, a resident of this legal entity, if such a physical person is a student, trainee or trainee or teacher, Professor, Lecturer, instructor, researcher or scientific colleague, corresponding services of Tax Compliance, which are announced at the current convention;

     d) it is established that the determining jurisdiction should provide for the tax or the determination of the number of residents of this determining jurisdiction in the field, which can be attributed to another determining jurisdiction in the field compliance with the tax code, which is published by the current convention (included, referring to the Permanent Representation, distributed in this other relevant jurisdiction, in compliance with the tax code, which the current convention);

     e) directed to the protection of residents of this dogmatic jurisdiction from alleged discrimination regimes of this dogmatic jurisdiction;

     f) allow residents of this dogmatic jurisdiction to be represented in a competent body of this or other dogmatic jurisdiction with the application of the tax code, or in accordance with the tax code, which is published by the current convention;

     g) it is possible to pay attention to the blocking of this identifying jurisdiction of a physical person, the resident of this identifying jurisdiction, if such a physical person is a co-worker of a diplomatic mission, a government mission or a consular mission determining jurisdiction;

     h) provide that pensions and other payments, based on compliance with legislation on social protection of other dogmatic jurisdiction, subject to taxation only in this other dogmatic jurisdiction;

     i) provide that pensions and analogous payments, annuities, alimony payments or other payments, which arise in another determining jurisdiction, are subject to tax blocking only in this other determining jurisdiction;

     j) iqim-another image directly determines the law on tax evasion of their residents or directly presupposes that the law on tax evasion of their residents in the country, which has the right to tax evasion in the country, has the right to tax evasion in this country in Doho.

     2. Point 1 is considered to be or at the request of the parties to the Tax Agreement, which is announced by the current convention, which is announced by the current convention, it will not be possible to apply to the tax agreement determining the jurisdiction of their residents.

     3. The Story can remain true:

     a) do not take full responsibility for your negative opinions, which are published by the current convention;

     b) do not take full responsibility for your negative opinions, which are published by the current convention, which are regulated by law, issued at Point 2.

     4. Every Story, which was not sent to the head of the department at A) or B) Point 3, contains the volume of depositions, which are related to each of the listed agreements, which are published at the current convention, the date, specified in point 2, and if it is sent to the number "I don't know," he said. If all the relevant jurisdiction has been approved in respect of tax claims, which are published by the current convention, such claims are imposed on points 1. In other cases, point 1 imposes its own tax agreement, which is announced at the current convention, only in the wedding anniversary, in such cases it is impossible with Point 1.

PART IV. CHANGING THE STATUS OF PERMANENT REPRESENTATION

Article 12-isual revision of the status of post-representation for the consideration of agent agreements and analog strategies

     1. consideration of tax claims, which are published by the current convention, defining the term "permanent representation", with reference to point 2, if a person is in a certain jurisdiction, which has a number of tax claims, which are made in accordance with the law of the Republic of Kazakhstan "on tax claims", which are made in accordance with the law of the Republic of Kazakhstan "on tax claims ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"", ""on tax claims"". " the current convention, based on the activities of enterprises and, as such, usually concludes contracts or generally plays a major role in the conclusion of contracts, which are regularly concluded without significant changes business, and these contracts:

A) from the ownership of enterprises, or

     b) for those who pass the law on property, or provide for the use of property, which is owned by the company, or in respect of which the company deals with the law on use, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or in respect of property, or

     c) for the purpose of providing services Etim enterprises,

     such a business will be considered as a permanent representation in this jurisdiction in relation to the love of business, which such persons rely on for business, for the exclusion of technical workers, as well as such activities, according to the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic of Kazakhstan, the Ministry of education and science of the Republic Of according to the law of the Republic of Kazakhstan, it is announced by the current convention (with changes, which may be established by the current convention).

     2. Point 1 does not apply, if a person, as one of the relevant jurisdictions, which is subject to strict tax law, which is published by the current convention, from which enterprises belong to another relevant jurisdiction, which follows entrepreneurial activity is first determined by the jurisdiction in the quality of the agent with an unsolicited status and acts for business within its specific activities. One way or another, if a person is interested or mainly interested in the identity of one or other enterprises, with which it is connected, this person will not be considered an agent with an unsolicited status in relation to the love of such enterprises in the knowledge of those present in point.

     3. a) point 1 refers to the total amount of tax revenue, which is distributed by the current convention, which determines the conditions, at which enterprises are considered as having a permanent representation in a certain jurisdiction (or persons as a permanent representation in a certain jurisdiction) in relation to activity, which is a person, Foreign, who is an agent with an unspecified status, depends on the company, but only on the wedding anniversary, when such changes occur in the situation, such persons have and generally use the full term to conclude contracts from the ownership of enterprises in this jurisdiction.

     B) Point 2 provides for the introduction of a tax agreement, which is published by the current convention, which provides that the company should not consider as a permanent representation in a certain jurisdiction in respect the activity of an agent with an unspecified status depends on this enterprise.

     4.it is possible to maintain the right to do so, but not to take full responsibility for the current status in relation to it, which is announced by the current convention.

     5. every date, which was not assigned to the head of state, should be approved at Point 4, the deposit on each of its own tax payments, which is published by the current convention, which is approved in Lieutenant Colonel A) at point 3, as well as the number of articles and points every so often. Point 1 will be applied in relation to the tax assessment, which is published by the current convention, only if all the relevant jurisdiction is determined in respect of this assessment.

     6. Every Story, which was not sent to the source, should be approved at Point 4, the depositary of each of its own taxable claims, which is published by the current convention, which is approved by Lieutenant Colonel b) at point 3, as well as the number of articles and points every so often. Point 2 is applied in relation to the tax assessment, which is published by the current convention, only if all the relevant jurisdiction is determined in respect of this assessment.

Article 13-isual revision of the status of permanent representation for inclusion, foreseen for concrete views of activity

     1.The Story can specify libo point 2 (option a), libo point 3 (Option B), libo can not specify one of the options.

      Variant A

     2. in accordance with the current convention, which defines the term "post-representation", the term "post-representation" does not include in the SEB:

     a) views on activities, specifically committed in parallel, on which the current convention is published (until changes, the current convention) as activity, which is not considered as an established representation, in the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan, the presence of the Republic of Kazakhstan.;

     b) coordination of activities in the post-location is necessary for the purpose of ensuring the interests of the enterprise for the development of Love activities, not approved in lieutenant colonel a);

     C) coordination of activities in the post-location is necessary for the establishment of a love combination of views of activities, approved in Sub-Divisions A)and b);

     at the same time, such activities or, in the case of the Lieutenant Colonel), joint activities at the post-Soviet place of activity, are considered preparatory or comprehensive characteristics.

      Option B

     3. in accordance with the current convention, which defines the term "post-representation", the term "post-representation" does not include in the SEB:

     a) views on activities, specifically laid down in parallel, on which the current convention (until changes, the current convention), which are not considered as activities, the image of a permanent representation, it is impossible to exclude from it the importance of post-presentation activity of the educational or educational character; in a number of cases, when the relevant provision of the Tax Agreement to which this Convention applies explicitly establishes that a certain activity is considered not to be linked to the formation of a stable concept if it is preparatory or universal in nature.;

     (b) The maintenance of a sustainable place of business for the purpose of providing any activity not specified in subparagraph (a), provided that such activities are preparatory or universal in nature;

     C) coordination of the activities of the Post-place of employment is necessary for the development of the love of the combination of views of the activities, approved in the sub-branches A) and b), with the provision that the joint activities of the Post-place of employment in the result of such a combination will be considered as a training or a fascinating character.

     4. confirmation of Tax Compliance, which is announced at the current convention (with reference to changes, which can be made at Point 2 or 3), in which special views of activity, which are not considered by the image of the post-presentation, are not considered it is distributed at the permanent place of activity, use or use of enterprises, if it is connected with other enterprises that operate the business in the same place or in another place in the wedding. determining the jurisdiction:

     a) this place or other place is intended for the education of post-office representation for enterprises or especially related enterprises in accordance with the provisions of the tax code, which is published by the current convention, which determines the post-office representation, or

     b) joint activity in the result of the combination of activities, which are based on two enterprises in the workplace, or also on enterprises or specially connected enterprises in two places, does not imply preparatory or comprehensive characteristics, under conditions, the activity is based on two enterprises in the same place, or also on enterprises or specially connected enterprises in two places, which represent so-called interconnected functions that are part of a single business process.

     5. a) point 2 or 3 refers to the corresponding tax payments, which are distributed to the current convention, in which special views of activities are passed, which are not considered as an image of a permanent representation, but also IFLI activity is carried out through a permanent place of activity (or partial agreement, which is distributed according to the current convention, which is analogous to the image).

     b) Point 4 is applied to tax payments, which are distributed according to the current convention (with reference to changes, which can be made at Point 2 or 3), which are transferred to special types of activities, which are not considered in the form of post-registration representation, however, is carried out through a permanent place of activity (or partial agreement, which is published by the current convention, which is analogous to the image).

     6. The Story can remain true:

     a) do not take full responsibility for the current status in respect of negative opinions, which are published by the current convention;

     b) it is not necessary to take into account Point 2 in relation to negative opinions, which are published at the current convention, which directly establish that special views of activity are not considered as an image of such views, only if they are from such views activities are about caring or caring characters;

     C) do not take into account Point 4 in respect of negative opinions, which are published by the current convention.

7.every story, which was chosen as a variant according to point 1, should be provided with a deposit on your chosen variant. This agreement also includes all tax agreements, which are issued at the current convention, which are approved in lieutenant colonel a) at point 5, as well as at the number of articles and at the same point. The option will be applied in relation to the tax assessment, which is published by the current convention, only if all the relevant jurisdiction will be removed one and the same option and will be implemented in respect of this law.

     8. every story, which was not made by the head of state, not specified in Lieutenant Colonel A) or C) at Point 6, and not released from one of the options according to point 1, contains depositions about each one's own negative agreement, which is published by the current convention, which deals with 5 points, as well as the number of articles and such points. Point 4 is applied in relation to the tax assessment, which is published by the current convention, only if all the relevant jurisdiction is determined in respect of this assessment according to the current point or point 7.

Article 14-disclosure of contracts

     1. it is also important to note that in order to determine the period (period), which is extended in the field of Tax Accounting, which is published by the current convention, which is defined by the period (or period) time, after which specific objects or activities are carried out images of post-presentation:

     A) if the business of a dogmatic jurisdiction operates in another dogmatic jurisdiction, which depicts a construction site, a construction or installation object or another concrete object, determined in appropriate conditions Tax Compliance, which is announced by the current convention, or follows the expected or consultative activity in relation to such a place, in respect of tax compliance, which is announced by the current convention, which is related to such views activities, and these types of activities are carried out in one or several periods, which in combination prevent 30 days without the Prevention of periods or periods, approved in accordance with the Tax Agreement, which is announced at the current convention; and

     b) if connected views of activities are carried out in this other relevant jurisdiction for a wedding on a construction site, a construction or installation object or another place, determined in accordance with the tax legislation, which the current convention (or, if applicable, the corresponding tax agreement, which is published in accordance with the current convention, is applied to limited or consultative activities, related to them), in different periods of time, every from these last 30 days, one or several enterprises, connected with the first company,

     such different periods of time are added to the combined period of time, in which the first large-scale enterprise is based on activity at this construction site, construction or installation facility or other place, determined in corresponding there is a negative attitude towards the current convention.

     2. Point 1 is taken into account or at the end of the Tax Agreement, which is announced at the current convention, in the wedding period, such agreements are concluded to conclude contracts in a separate part with the purpose of consideration of the deadline or measures in respect of post-registration representation for concrete objects or views of activities, ordered in point 1.

     3. The Story can remain true:

     a) do not take full responsibility for negative opinions, which are published by the current convention;

     b) do not take full responsibility for the current status in respect of tax payments, which are distributed by the current convention, linked to the development or development of private resources.

     4. Every Story, which is not assigned to the head of the department, not assigned to the Lieutenant Colonel A) at Point 3, contains the volume of deposits, which includes some from it taxable items, which are distributed to the current convention, the bill, not assigned to point 2, which is not provided for by the head of State in accordance with the lieutenant colonel B) at Point 3, and if so, the number of items and such items at the point. If all the relevant jurisdictions have agreed on such an agreement, which is published by the current convention, such agreement is imposed on the terms at Point 1 in the wedding anniversary, as it was proposed in point 2. in other documents at Point 1 it is established that the current convention is announced only on the wedding anniversary, in which such agreements are not reached with Point 1.

Article 15-determination of persons related to business

     1. For the purposes of the tax assessment, which is published at the current convention, there are amendments to point 2 of Article 12 (isual revision of the status of post-representation for the consideration of agent agreements and analog strategies), point 4 of Article 13 (isual changes in the status of Permanent Representation for certain types of activities) or Point 1 of Article 14 (agreement of contracts), people are strongly associated with enterprises, if they are based on all relevant facts and obstetrics, one person has control over another, or the plague is under the control of one and the same persons or enterprises. In love with the company, if the beneficiary's share of participation in other companies directly or by virtue of more than 50 percent (or, in the case of the company, more than 50 percent of Joint Stock Companies and stock companies, or 50 percent of shares) is considered to be tied up with the company's business, or 50 percent of the share company's participation in other companies is considered to be more than 50 percent of the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company's participation in the share company Joint Stock Company), or if the beneficiary's share of participation in other persons in the company and in enterprises directly or directly consists of more than 50 percent (or, in the case of the company, more than 50 percent of Joint Stock Companies and stock companies or 50 percent of joint stock companies).

     2. According to the report, 4 articles 12 were issued at points (ISBN status of post-representation for agent agreements and analog strategies), lieutenant A) or C) at Point 6 Articles 13 (ISBN status of post-representation for a) in point 3 of Article 14 (agreement of contracts), it is possible to remain true or not to take full responsibility for the current status to the current convention, which is published by the current convention, to which these lights are applied.

Part V. improving the mechanism for the development of sports

Article 16-intramuscular procedure

     1. if a person believes that the same or related jurisdictions do not accept or accept his or her marriage agreement, which is announced by the current convention, he or she may not accept it sources of protection, provided for by national legislation of these determining jurisdictions, represent a competent body of love from determining jurisdictions. The application should be presented in three years with the moment of first approval of the activities, which are carried out to prevent corruption, or in accordance with the laws of the Republic of Kazakhstan, which are published by the current convention.

     2. a competent body will be able to decide on the issue, if it is decided to appeal to the authorized body, and if it is not possible to apply for an effective decision, on mutual agreement with a competent body of another determining jurisdiction with a target of tax evasion, there is no corresponding agreement on which the meeting will be held. It is necessary to agree on the need to issue from time immemorial, established by the national legislation of the relevant jurisdiction.

     3.competent authorities of the right of jurisdiction will be able to develop mutual understanding of their love for labor or somneniya, arising at the level of toleration or at the level of Tax Compliance, which is announced by the current convention. They will also be able to consult with other people with the purpose of maintaining double taxation in families, not provided for by the current convention.

      4. a)  

     I) the first proposal at Point 1 is given either by the resolution of the Tax Agreement, which is published by the current convention (or their parts), which presupposes that if people consider that the same or related jurisdictions the convention, which is published by the current convention, which can be made from the sources of protection, provided for by national legislation, is not subject to verification. jurisdiction, to represent a competent authority that determines the jurisdiction, he is a resident, included in the list of persons, if he is represented by a person, under the Tax Agreement, which is published by the current convention, which includes non-discrimination on a national basis, the application can be represented by a competent authority that determines the jurisdiction, and the National person it is;

ii) the second proposal at Point 1 is submitted to the Tax Agreement, which is announced by the current convention, which provides that the first proposal at Point 1 should be presented in the final period of time there is a three-year period with the moment of first approval of the activities, which are carried out not in accordance with the tax legislation, which is published by the current convention, or at the request of the tax code, which is published the convention, during the decisive period of time, such an application must be presented.

      b)  

     I) the first proposal at Point 2 is made at the request of the Tax Agreement, which is published by the current convention, which provides that a competent authority, which is represented by a person, approved at Point 1, will stretch, if it is ten years old if it is not possible to apply for an effective resolution, to resolve the issue of mutual agreement with a competent authority of another determining jurisdiction, with the purpose of ensuring the protection of property rights, or in accordance with tax law, for which the current convention is announced.

     ii) the second proposal at Point 2 is to consider the total number of tax payments, which is announced by the current convention, which stipulates that a good reaching agreement must be issued without the need for loving time payments, provided that national legislation is determined by the jurisdiction.

      C)  

     I) the first proposal at Point 3 is to take into account the number of negative opinions, which are published by the current convention, which presupposes that the competent authorities of the right jurisdiction will be able to stretch to develop mutual understanding of their loved ones labor or somnambulism, rising at the level of toleration or at the level of Tax Compliance, which is announced by the current convention.

     ii) the second proposal at Point 3 is to consider the following tax agreements, which are published by the current convention, which stipulates that the competent authorities can also consult with other people in order to address two tax issues in the servants, or the current convention is represented by predetermined criteria.

     5. The Story can remain true:

     a) do not take the first proposal at the point of 1 K of its negative opinions, which are published by the current Convention, on the basis of which it is recommended to comply with the minimum standard for improving the mechanism for the development of sports within the BEPS plan, provided that according to some of their negative opinions, which are published by the current convention (inim, the negative opinion, which is published by the current convention, which allows the person to present the business of a competent body of Love from the relevant ones jurisdiction), if a person sees, the activity of the same or related jurisdictions is not subject to its blocking, nor in accordance with the laws of the Republic of Kazakhstan, which are published by the current convention, which does not contain from the number of security guards, provided for by the law of the Republic of Kazakhstan. according to the national legislation, this person can represent a competent body of a competent jurisdiction, he or she is a resident, or, if he or she is represented by a person, who receives a tax deduction, for which he or she is a resident the current convention, in addition, it is necessary to ensure the implementation of the state policy of the Republic of Kazakhstan, as well as to ensure the implementation of the state policy of the Republic of Kazakhstan in the field of Public Procurement, as well as to ensure the implementation of the state policy of the Republic of Kazakhstan in accordance with the legislation of the Republic of Kazakhstan.judging by the jurisdiction, which is a competent authority, it was proposed to apply for an intercollegiate procedure, or not to apply for a registered tax collector.

     b) do not take the second proposal at Point 1 for your negative opinions, which are published by the current convention, which does not provide for the application, which is to be submitted at Point 1 of the first proposal, which should be presented in the final period of time in addition, it is recommended to comply with the minimum standard for improving the mechanisms for the development of sports within the BEPS plan, ensuring that all these tax payments are distributed at the current convention, which is approved at Point 1, it is necessary to submit an application in June just three years from the moment of first approval of the activity, which is not related to tax regulation, which is published by the current convention.

     c) do not take the second proposal at the point of 2 for your negative opinions, which are published by the current Convention, on the basis that for all their negative opinions, which are published by the current convention:

     i) love to agree, reach a mutually beneficial procedure, which must be carried out without regard to certain areas of national legislation in the relevant jurisdiction; or

     ii) it is recommended to comply with the minimum standard for improving the mechanism for the development of sports within the framework of the BEPS plan, taking into account the adoption in its bilateral agreements on cooperation, that:

     A) determining the jurisdiction does not correct, which is related to the Permanent Representation of enterprises of one of the determining jurisdictions after the period of time, which is strictly agreed between the determining jurisdiction jurisdiction, at the end of the tax year, in which it was transferred to permanent representation (this measure is not applied in the Ministry of Agriculture, dressing gown or compulsory health insurance); and

     C) the established jurisdiction does not include business and does not correspond to the tax code of the Republic of Kazakhstan, which was initiated by the enterprise, but according to the conditions, approved in accordance with the tax code, which is distributed to the population the convention, which deals with associated enterprises, was not started, after the period of time, which was closely agreed between the relevant jurisdictions, from the end of the tax year, in which it was started. "I'm sorry," he said., a large bathrobe or an unfortunate lack of care).

     6. A) Every Story, which was not sent to the head of the department a) point 5, which is provided by the depositary of the volume, which is related to each of the tax agreements, which are published in part I) lieutenant a) point 4, and if you are interested in the number of items and points of each such item. If all the relevant jurisdiction has been approved in respect of Tax Compliance, which is announced by the current convention, then the first proposal is imposed at Point 1. In other cases, the first proposal at Point 1 imposes its own tax agreement, which is announced at the current convention, only in the wedding anniversary, in such cases it is impossible to say with this proposal.

     b) every Storona, which is not covered by the fire, is assigned to the Lieutenant Colonel b) at point 5, the Depositary:

     i) the passage of their tax agreements, which are announced at the current convention, which contain provisions, presupposes that the application, which is said in the first proposal at Point 1, should be presented in the final period of time there is a three-year period with the moment of first approval of the activity, which is carried out by the convention, as well as the number of articles and points of each such agreement; according to the current convention, the second proposal is made at 1 point, if all the relevant jurisdiction has been approved in such terms; in other cases, with Part ii), the second proposal at 1 point it is established that the current convention will be signed only on the wedding anniversary, in which such agreements are not included in the second proposal at Point 1;

     (ii) In accordance with their tax agreements to which this Convention applies, which are contained in a provision suggesting that the application referred to in the first sentence of paragraph 1 must be submitted within a certain period of time, amounting to at least three years, from the first introduction of activities involving taxation not in in accordance with the provisions of the Tax Agreement to which this Convention applies, as well as the article and paragraph number of each such provision; the second proposal at Point 1 does not apply to the Tax Agreement, which is published by the current convention, if the jurisdiction that is interested in such a tax agreement, which is published by the current convention.

     C) every Storona is supported by the Depositary:

     i) the passage of their tax agreements, which are published by the current convention, which is not regulated, in part I) lieutenant b) Point 4; the first proposal at Point 2 is submitted to the Tax Agreement, which is published by the current convention, only if all relevant jurisdictions have agreed on such an agreement, which is announced by the current convention;

ii) in the case of a report, not submitted, not submitted in Lieutenant Colonel C) at point 5, the transition to its own tax agreements, which are published by the current convention, which is not approved in Part ii) at Lieutenant Colonel b) at Point 4; the second proposal is submitted at Point 2 it is applied to the tax agreement, which is published by the current convention, only if all the relevant jurisdictions have agreed to such an agreement in relation to this tax agreement, which is published by the current convention;

     (d) Each Party is aware of the Depositary's:

     i) the passage of their tax agreements, which are announced by the current convention, which is not related, in part I) lieutenant C) at Point 4; the first proposal at point 3 is made to the Tax Agreement, which is announced by the current convention, IFLI only all relevant jurisdictions have agreed on this agreement, which is announced by the current convention;

     ii) the transition of their negative opinions to the current convention, which does not correspond to the current Convention, approved in Part ii) lieutenant C) Point 4; the second proposal to the negative opinion at Point 3, which is announced to the current convention, IFLI only all relevant jurisdictions have agreed on such an agreement, which is announced by the current convention.

Article 17-symmetrical corrections

     1. If a dogmatic jurisdiction includes a business in this dogmatic jurisdiction and is accordingly subject to a tax, in respect of which a business in another dogmatic jurisdiction is subject to a tax in this other dogmatic jurisdiction jurisdiction, as well as an image, which is the beginning of the first comprehensive determining jurisdiction, if we are talking about two enterprises, as we are talking about non-profit enterprises, in this regard, another determining jurisdiction performs appropriate correction of the amount of debt, which is taken from it. According to the resolution, such proofreading is necessary to study other aspects of the tax code, which are published by the current convention, and competent authorities of the relevant jurisdiction consult with other people.

     2. Point 1 is based on the assessment of the amount of tax, which is calculated from the amount of tax, which is calculated from the amount of tax, which is calculated from the amount of business that determines the amount of tax, if any other determining jurisdiction it includes this other dogmatic jurisdiction, and accordingly, the image of this other dogmatic one, which was started by this other dogmatic one jurisdiction, if we are talking between two enterprises, we are doing so, how to meet unsolicited businesses.

     3. The Story can remain true:

     a) do not take full responsibility for your negative opinions, which are published by the current convention, which is regulated in point 2;

     b) do not take full responsibility for your negative opinions, which are distributed by the current Convention, on the basis of which the agreement is signed at Point 2, in their negative opinions, which are distributed by the current convention:

     i) it provides adequate correction, prescribed in point 1; or

     ii) it is a competent body that will be able to resolve the issue in accordance with the requirements of the tax code, which is published by the current convention, which includes the interrelationship procedure.

     c) in the case of a report, which was made by the head of State in accordance with Part ii) lieutenant C) in point 5 of Article 16 (a comprehensive procedure) or to take full responsibility for its negative opinions, which are published by the current convention in addition, in its bilateral negotiations, it takes such a step according to the law of the Republic of Kazakhstan at point 1, under the condition that the relevant jurisdiction has reached agreement on such a step or a step, approved in Part II) Lieutenant Colonel s) in point 5 Article 16 (intramuscular procedure).

     4. every date, which is not specified in point 3, contains the volume of depositions, which are related to each of the listed agreements, which are published at Point 2, and if so, the number of articles and points of each "I'm sorry," he said. If all the relevant jurisdictions have agreed on such an agreement, which is announced by the current convention, such agreement should be imposed on points 1. In other cases, point 1 imposes its own tax agreement, which is announced at the current convention, only in the wedding anniversary, in such cases it is impossible with Point 1.

 PART VI.ARBITRATION

 Article 18-decision on Part VI

     It is possible to adopt a decision on the current part of their tax agreements, which are published by the current convention, and the corresponding image is based on this Deposit. The current part is related to two related jurisdictions, which are represented by the current convention, as long as the relevant jurisdiction has been strengthened.

 Article 19-mandatory for execution of Arbitration resolution

     1. Yesli:

     a) in accordance with the Tax Agreement, which is published by the current convention (with reference to the amendments, which can be made at Point 1 of Article 16 (visual inspection procedure)), which provides the opportunity for people to represent the business in the Competent Authority of the relevant jurisdiction, if it follows that one or more relevant jurisdictions attract or attract in respect of the same person to the tax code, or in accordance with the requirements of the tax code, for which the current convention is announced, these may be established by the current convention), the person presented in the competent authority to determine the jurisdiction on the basis of the volume, that the activity of the same or related jurisdictions is carried out in relation to this person for rehabilitation or compliance with the amendments to the tax agreement, which is announced by the current convention (with the amendments, which may be established by the current convention); and

     b) competence bodies or in the context of reaching agreements on the development of this business in accordance with the current convention (with reference to changes that can be made at Point 2 of Article 16 (intramuscular procedure)) it is envisaged that the Competent Authority will be able to decide on mutual agreement with the competent authority in the two-year period, starting from the date, specified in point 8 or 9, in accordance with the requirements of the concrete law (Krome sluchaev, according to the establishment of this period, the competent authorities of the relevant jurisdiction have been established at the Foreign time period for this purpose and have been determined by these persons, presented at the consideration),

     dear questions, which are relevant in connection with the business, on the basis of the pussy image of the person presented to the consideration of arbitration proceedings, announced in the current part, in accordance with the laws and procedures of the competent authority determining the jurisdiction in accordance with the provisions of point 10.

     2. if a competent authority has submitted a comprehensive procedure, prescribed in point 1, as in the case of one or other minor issues, it is considered in the water or Administrative Tribunal, the procedure for the period, established in lieutenant B) at Point 1, it is expected that until now, PKA libo will not be recognized as an important decision on the water or in the Administrative Tribunal, PKA libo will not be considered. In addition, if a person presents a case for consideration, and a competent authority has agreed on the appointment of an intercollegiate procedure during the period, established in lieutenant colonel b) at Point 1, it is noted that such a request will not be canceled.

     3.if the plague of a competent body was considered, it was not provided with its own useful information materials, which were published from a competent body after the beginning of the period, which was established in the Lieutenant Colonel b) at the point 1, for the period, established in lieutenant colonel B) Point 1 continues at the time, the same period, starting with the date of information and entering the date, when such information was presented.

     4. a) resolution of Arbitration in respect of issues, presented at the consideration of arbitration, is carried out in accordance with the law of the Republic of Kazakhstan, approved at the point 1.resolution of arbitration is relevant.

     b) resolution of arbitration shall be related to the relevant jurisdictions, for the exclusion of the following persons:

i) if a person who is not considered to be an unsolicited person, does not have a clear opinion, which will lead to the execution of the arbitration decision. In this regard, it is not necessary to conduct further consideration of the competent authorities. It is agreed that the resolution of Arbitration on this issue is considered by an unsubstantiated person, an unsubstantiated subject, if a loved one, an unsubstantiated subject, will not be considered in 60 days with the date of its execution persons on mutual agreement, with consideration of all issues, decisions on mutual agreement, which will lead to the execution of the arbitration decision, or in a foreign image, will prekratize the beloved unspecified court or administrative reforms in relation to these issues, this corresponds to an informed mutual understanding.

     ii) if a significant decision of the court of one jurisdiction is made, the decision of arbitration is not binding. In addition, it is considered that the provisions of Arbitration in accordance with Point 1 were not presented, the arbitration process was not followed (as for the purposes of statutes 21 (confidentiality of arbitration procedures) and 25 (Terms of arbitration procedures). In addition, a new reserve for arbitration can be represented, if only the competent authorities do not agree on the lack of such a new reserve.

     iii) if a person who is unlawfully affected by the case under consideration applies to a court or an administrative tribunal on issues that were resolved by mutual agreement, brought to enforce the arbitration award.

     5. The competent authority that received the initial request for a comprehensive procedure, as specified in subparagraph (a) of paragraph 1, within two calendar months of receipt of the request.:

     a) directs people, representing this business, which he received; and

     b) directs the implementation of this document with a copy of the document in a competent authority other relevant jurisdiction.

     6. in the study of three calendar months with the moment of obtaining a competent authority, the procedure for conducting an intercollegiate procedure (or its copy from a competent authority in another jurisdiction), ten or:

     (a) Informs the person presenting the present case and the other competent authority that he has received the information necessary to examine the merits of the case; or

     b) publishes additional information from this person for these people.

     7. if according to the Lieutenant Colonel B) at point 6, one or the plague of a competent body was sent to a person, represented this business, additional information, necessary for consideration of the case on the issue, competent body, stored additional information, in the third stage calendar months on receipt of additional information from this person will be provided by this person and other competent authorities of the volume, that:

     a) he received stored information; or

     b)that part of the stored information is sucked out.

     8. if any of the competent authorities did not send additional information according to the Lieutenant Colonel B) at Point 6, the first date, the date is 1, there is a significant increase in income from the following Danish:

     a) the date when the plague of the competent authorities was inflicted by a person, represented by the Lieutenant Colonel a) at Point 6; and

     b) the date of establishment of three calendar months with the moment of establishment of a competent authority of another jurisdiction according to the Lieutenant Colonel b) point 5.

     9. additional information was sent to the Lieutenant Colonel B) at Point 6, Starting date, ending at Point 1, there is a significant increase in revenue from the following Danish:

     (a) The latest date on which additional information was compiled, the person who submitted the case and another competent authority were entered in accordance with paragraph 7 (a); and

     b) the date of establishment of three calendar months with the moment, when the plague of the competent authorities received all the information, which is loved by those of the competent authorities represented by the company.

     If, by the way, one or the other competent authorities of the plague are directed to recovery, which is carried out in lieutenant b) at Point 7, as well as in compliance with additional information with Lieutenant B) at point 6.

     10. competent authorities of the relevant jurisdiction establish mutual agreement (according to the article of the corresponding tax agreement, which is published by the current convention, regulating the procedure for achieving mutual agreement), the current part includes a minimum amount of information, which is necessary for every competent body to consider the case. This agreement is concluded until the date, when the relevant issues are resolved to consider the terms of Arbitration, and the time from time to time can be corrected.

     11.for those who have the right to refer to their negative opinions, which are published by the current convention, it is possible to stay for the next two-year period, established in lieutenant colonel B) at Point 1, three-year period.

     12. The Story can be left by the same law to take into account the following laws in respect of their negative opinions, which are published by the current convention, which does not contain other relevant articles:

     a) a loved question, which arose during the visit to the arbitration procedure, which in a foreign session was discussed within the framework of the arbitration procedure, the planned meeting, which is not presented at the consideration of arbitration, if the decision is made on this issue the issue was resolved by the court or the Administrative Tribunal of the beloved from the determining jurisdiction;

     b) if at the moment of love, after the presentation of the Arbitration Commission and the resolution of the competent authorities of the jurisdiction, the decision on this issue will be made by the court or the Administrative Tribunal of the same name jurisdiction, to arbitration procedure precedes.

Article 20-Appeal Of Arbitrators

     1.due to the inclusion of employees, when the competent authorities of the relevant jurisdictions have agreed on other rules, for those who have a part of points from 2 to 4.

     2. following rules regulate the attention of members of the Arbitration Commission:

     a) The Arbitration Commission is composed of non-qualified arbitrators, relevant competencies or experience in international issues on tax issues.

     b) every competent authority pays one member of the commission for 60 days from date of receipt of arbitration with paragraph 1 of Article 19 (mandatory for the execution of the resolution of Arbitration). Two members of the Arbitration Commission, named such images, in the period of 60 days from the moment of their consideration, will be the chairman of the Arbitration Commission. The chairman is either a citizen or a resident lover from a certain jurisdiction.

     c) every member of the arbitration commission should be independent and independent from competent authorities, tax administrations, ministries of Finance, which have jurisdiction and from all persons, who are not subject to law, (as well as their councils) in during the adoption of its priority, to ensure its non-compliance and non-compliance in the development and implementation of the unified period of time, it is possible to determine the direction of non-compliance and non-compliance of arbitrators in the direction "no," he said.

     3. in the case of a competent body that does not determine the jurisdiction, there are no members of the Arbitration Commission at the same time and in the period of technical time, which were given at point 2 or agreed between the competent authorities of the jurisdiction, the arbitration commission it is noted that this is a competent body that should be the highest center of Tax Policy and Administrative Organization of Economic Cooperation and development, which does not have a citizen's love from a certain jurisdiction.

     4. If two members of the Arbitration Commission are not appointed by the chairman at the same time and in the period of technical time, which were agreed at point 2 or agreed between the competent authorities to determine the jurisdiction, the chairman is appointed by the highest duty a person in the center of Tax Policy and administration of the organization of Economic Cooperation and Development who does not have a citizen's love from the jurisdiction.

Article 21-confidentiality of arbitration procedures

     1. It is also important to consider the priority of the current part and the corresponding tax agreement, which is published by the current convention, as well as the national legislation, which determines the jurisdiction in terms of information, confidentiality and administrative assistance, members of the Arbitration Commission and as much as possible to three partners from each member commission (as well as potential arbitrators in the wedding period, which is necessary for their assistance to be paid, provided to arbitrators) are considered by persons or bodies, it is possible to disclose information. Information, received by the arbitration commission or potential arbitration, and information, received by the competent authorities from the Arbitration Commission, is considered to be information, which is transmitted in accordance with the tax agreements, which are published at the current convention the issues of information and administrative assistance are discussed.

2. The competent authorities of the Competent Jurisdiction guarantee that the members of the Arbitration Commission and their associates will be able to establish their activities within the framework of the arbitration procedure, in the official form to disclose the information they love the arbitration procedure, in accordance with the requirements of confidentiality and non-compliance, regulated in the tax code, which is published at the current convention, which is related to information and administrative assistance, and in accordance with the priority legislation of the determining jurisdiction.

Article 22 - resolution to arbitration proceedings

     For the purposes of the current part and the corresponding tax agreement, which is published by the current convention, which provides for the development of mutual agreement, mutually beneficial procedure, as well as arbitration procedure, in relation to the dela it is noted that if we have a good moment after the end of the year, as the Arbitration Commission has passed its resolution of competent authorities of the jurisdiction:

     a) competent authorities of certain jurisdictions achieve mutual agreement in the resolution of the case; or

     b) the person, representing the case, is obliged to submit an application for arbitration or to submit an application for an intercollegiate procedure.

Article 23 arbitration procedure

     1. due to the inclusion of employees, the competent authorities of the relevant jurisdiction were closely related to foreign laws, in accordance with the current part of the following rules in the arbitration procedure:

     a) after consideration of Arbitration, the Competent Authority of each jurisdiction presents the Arbitration Commission for the date, established agreement, the proposal to approve all unspecified issues (issues) on the matter (taking into account the introduction of all agreements has reached the agreement between competent authorities of the relevant jurisdiction). The proposed decision is aimed at expanding the amount of determined bodies (orders, orders or orders) or, if it is clearly defined, the maximum tax rate, provided in accordance with the Tax Agreement, which is distributed the current convention, for every proofreading or a direct question to do so. At the same time, the competent authorities of the relevant jurisdiction did not reach the agreement on the corresponding tax agreement, which is announced by the current convention (also - "basic question"), on the basis of which residency is carried out physical person or Post-Office representation, competent authorities can present alternative proposals for resolution of issues, the resolution of which is supported by the resolution of major issues.

     b) a competent authority of any jurisdiction can also present to the consideration of the Arbitration Commission's supporting position in the document. Every competent body, representing the proposal for resolution or supporting position of the document, directs the copy of another competent body to the date, when the proposal for resolution or supporting position of the document is necessary to provide. Every competent body can also present an arbitration commission at the date, established by agreement, an answer to the proposals of other competent bodies for resolution and supporting the document. Copy love's responsible position is represented by another competent body at the date, when the responsible position should be provided.

     c) The Arbitration Commission considers its decision as one of the proposed decisions on the matter, which were presented by competent authorities in relation to each issue and the main issues, and does not include the announcement or any other clarification on the resolution. The arbitration decision is made by a large number of members of the Arbitration Commission. The arbitration commission will make its decision in the pussy of the competent authorities of the jurisdiction. Arbitration decision does not have a precedent.

     2.for those who have the right to refer to their negative opinions, which are published by the current convention, it is possible to remain true or to apply Point 1 to their negative opinions, which are published by the current convention. According to the expert opinion, the competent authorities of the relevant jurisdictions are closely related to other laws, in respect of which the arbitration procedure is subject to the following rules:

     a) after the consideration of Arbitration, the Competent Authority of each jurisdiction presents the necessary information, which can be necessary for the adoption of arbitration decisions, all members of the arbitration commission without undiscovered obligations. Unless otherwise agreed by the competent authorities of the Contracting Jurisdictions, any information that was underestimated by the competent authorities before they received the arbitration fee will not be taken into account for decision-making purposes.

     b) The Arbitration Commission takes a decision on issues of Arbitration, presented in accordance with the current convention, and with such rules, rules of national legislation determining jurisdiction. Members of the arbitration commission also study other citizens who can be directly represented by competent authorities who determine the way of interaction.

     c) the arbitration decision is transferred to the competent authorities of the jurisdiction in the legal form and determines the rights of the parties, which are considered, as well as the preparation of the results of the ratification. The arbitration decision is taken by a large number of members of the commission. Arbitration decision does not have a precedent.

     3. The Story, which was not approved by the head of State at Point 2, can not be left by the law, nor to take into account the previous points of reference to their negative opinions, which are published by the current convention, as well as the stories that were published the ogre. In this regard, the competent authorities of the relevant jurisdiction, which are distributed to the current convention, are determined to reach agreements on the type of arbitration procedure, which is proposed in the direction of such tax agreements, which are distributed "I don't know," he said. The same agreement is not reached, Article 19 (mandatory for the execution of the arbitration resolution) does not apply to this negative agreement, which is published by the current convention.

     4.it is also possible to decide on point 5 in relation to their tax obligations, which are distributed by the current convention, and the corresponding image is determined by this Depositary. Point 5 is based on the two relevant legal agreements, which are signed by the current convention, if we are interested in such agreements.

     5. until the beginning of the arbitration procedure, the competent authorities of the relevant jurisdiction in respect of tax disputes, which are published by the current convention, it is concluded that every person, representing the business, and their councils Dali agree in the pussy form I would like to inform another person about the information received during the arbitration procedure from the competent authority or the arbitration commission. The mutually beneficial procedure in accordance with the tax code, which is published by the current convention, as well as the arbitration procedure in accordance with the current part, which precedes the law, if at the time of love, as it was the provisions of Arbitration, and to the same extent, as the Arbitration Commission has passed its decision by competent authorities of the jurisdiction, the person represented by the case, or one of the councils of this person with a serious image, will draw such a conclusion.

     6. consideration at Point 4, the date, which is not resolved, does not apply to point 5, can be left for the same law or apply to point 5, which are distributed by the current convention, or in respect of all its members negative opinions, which are expressed by the current convention.

     7.on the basis of the resolution of Point 5, it is possible to remain true or not to take into account this part in respect of all negative opinions, which are published by the current convention, according to which other relevant jurisdiction acts according to point 6.

Article 24-agreement on foreign decisions

     1.for those who have the right to take part in the consideration of their negative opinions, which are published by the current convention, it is possible to decide on point 2 and the corresponding image of the Depositary. Point 2 is based on two specific tax agreements, which are published by the current convention, only in the case of such agreements, if the relevant jurisdiction has been strengthened.

     2. There are 4 points of Article 19 (mandatory for the execution of Arbitration), the resolution of Arbitration in accordance with the current part is not mandatory for the execution of certain jurisdictions, which are distributed to the current one the convention, and it is not intended to be implemented, if the competent authorities of the relevant jurisdiction agreed on foreign issues related to the procedure of three calendar months with the moment of transition to arbitration resolution.

3.on the basis of Paragraph 2, it is possible to remain within the framework of the law on Paragraph 2 only in respect of their negative opinions, which are published by the current convention, which is amended by Article 2 of Article 23 (type of arbitration procedure).

Article 25-arbitration proceedings

     During the arbitration procedure in accordance with the current part, the terms of Accession and compensation of different members of the Arbitration Commission, as well as those who are in connection with the arbitration procedure in accordance with the established jurisdiction, are not required determining the jurisdiction in such a way that it is possible to establish a mutual agreement between competent authorities of determining the jurisdiction. According to this agreement, each jurisdiction has its own accounts and accounts paid with it by the Arbitration Commission. The chairman of the Arbitration Commission and other representatives associated with the conduct of arbitration procedures that determine the jurisdiction in the lower reaches.

Article 26-Cooperation

     1. in accordance with Article 18 (resolution on Part IV), the current part of the tax agreement is submitted to the current convention, which provides for the conduct of Arbitration in respect the questions that arise from the business of the Intercollegiate procedure. Every story, which is decided to apply to the current part, is based on the volume of depositions, which are related to the current convention, i.e. technology, which is distributed in accordance with Point 4, so that the volume of depositions is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions, which is equal to the volume of depositions.and, if we are talking about the number of items and points of each such item. If there are two dogmatic jurisdictions, there is an agreement in respect of the tax law, which is published by the current convention, such a request is imposed on the current part of the law in respect of two such dogs between them jurisdiction.

     2. a question of interest, which arises from the business on the mutually beneficial procedure, which in a foreign session was considered within the framework of the arbitration procedure, the proposed part, is not addressed to the consideration of arbitration, if the issue is related to in particular, the arbitration commission or the governing body in accordance with the double or multi-storey agreement, which provides for the implementation of the resolution of Arbitration on unresolved issues, which arise from the dela the eye-piercing procedure.

     3. in accordance with Point 1, no less important part does not apply to the release of more relevant obligations in the direction of Arbitration consideration of unresolved issues, which arise in the context of the Intercollegiate procedure on the basis of other meetings, talks these determining jurisdictions are either settled or will be settled in the future.

     4. The Story can not be left for the same law, nor to take into account the existing part in the same or non-existing negative agreements, which are published by the current convention (or all other negative agreements, which are published by the current convention), which presupposes mandatory for the execution of the resolution of Arbitration on unresolved issues, which arise from the case on the Intercollegiate procedure.

  PART VII. EXCLAMATION POINTS

Article 27-entry and ratification, adoption or repayment

     1. starting from December 31, 2016, the current convention to sign up:

     a) all states;

     b) Guernsey (United Kingdom of Great Britain and Northern Ireland); Isle of Man (United Kingdom of Great Britain and Northern Ireland); Jersey (United Kingdom of Great Britain and Northern Ireland); and

     c) in accordance with the resolution on the basis of the consensus of the parties and the parties.

     2.the existing Convention shall be ratified, adopted or ratified.

Article 28-Ogovorki

     1. at the point where 2 no lights can not be held at the current meeting, due to the exclusion of technology, which is directly distributed:

     a) point 5 Articles 3 (fiscal-prosaic persons);

     b) Point 3 Article 4 (persons with dual residency);

     c) points 8 and 9 of Article 5 (introduction of methods of using two-way sanitation);

     d) item 4 Article 6 (specific tax agreement, which is announced by the current convention);

     e) points 15 and 16 of Article 7 (presupposition of evil deeds);

     f) item 3 Article 8 (operations on the transfer of dividends);

     g) point 6 Article 9 (income from payment of shares or share participation, the cost of which is represented by a pre-viable estate);

     h) point 5 of Article 10 (it was approved by the government of the Republic of Kazakhstan from the number of registered representatives, distributed in third jurisdictions);

     i) point 3 Article 11 (introduction of tax agreements in order to reduce the number of cases in the treatment of tax evasion of their residents);

     j) point 4 of Article 12 (isual revision of the status of post-representation for the consideration of agent agreements and analog strategies);

     k) point 6 of Article 13 (isual revision of the status of post-representation for consideration, foreseen for concrete views of activity);

     l) item 3 Article 14 (breakdown of contracts);

     m) Point 2 Article 15 (determination of persons, especially related to the company);

     n) Item 5 Article 16 (intramuscular procedure);

     o) item 3 Article 17 (symmetrical corrections);

     p) points 11 and 12 Articles 19 (mandatory for execution of Arbitration resolution);

     q) articles 23 with points 2, 3, 6 and 7 (type arbitration procedure);

     r) item 3 Article 24 (agreement on foreign decisions);

     s) item 4 Article 26 (co-operation);

     t) Points 6 and 7 Articles 35 (the beginning of activity); and

     u) item 2 Article 36 (the beginning of the activity Part VI).

     2. A) it is necessary from Point 1, the date, which in accordance with Article 18 (resolution on Part VI) will be determined by Part VI (arbitration), it is possible to form one or more sources in the consideration of the proposal, which will correspond to the terms of Part VI (arbitration the law on arbitration in accordance with the terms of Part VI (arbitration). To date, according to Article 18 (resolution on Part VI), it is planned to introduce Part VI, after which it will be held a meeting with the head of State, which should be held in the same time, that and improvement of the storon deposit in accordance with Article 18 (resolution on Part VI).

     b) lights, arranged in accordance with the lieutenant-colonel a) subject to adoption. According to Lieutenant Colonel A), it is noted that if he did not agree with the Depositary on the issue of increasing the number of deposits to the end of the period of two calendar months, starting from the date of settlement of the Depositary or until the date of settlement of the depositary the signing of the document on ratification, adoption or delivery, in accordance with the requirements of the Republic of Kazakhstan, which is from Denmark, is more favorable. For example, it is planned to issue Part VI (Arbitration) in accordance with Article 18 (decision on Part VI) after the meeting, as it was a meeting of the current meeting, the emergence of previous fire engines, other talks in accordance with the agreement a), it will be possible to increase the deposit amount during the first meeting in accordance with Article 18 (Part VI). If there is an increase in the number of fires, arranged in accordance with Lieutenant Colonel A), Part VI (arbitration) is not considered in relation to the relationship between the fire and the fire, the fire.

     2. if a foreign straight line is not provided for in corresponding fields of the meeting, the fire, arranged in accordance with Point 1 or 2:

     a) Changes for the parties, performing work on the fire, in which other events are held, to which the fire, in the wedding anniversary, in which it was envisaged; and

     b) at the wedding, they are transferred for other stories in relation to the story, which is happening to the fire.

     4. fires, priority for tax considerations, which are declared by the current convention, are concluded in the jurisdiction or territory or from their owners, for international relations of which there is no responsibility if this jurisdiction or territory does not have a storehouse meeting with Lieutenant Colonel B) or C) at Point 1 of Article 27 (entry and ratification, adoption or settlement), it is necessary to be responsible for the incident and can be removed from the fire, provided that this incident is related to their negative opinions, they are represented by an existing convention.

     5.the sources must be signed during the signing or at the end of the document on ratification, adoption or settlement with the passing of points 2, 6 and 9 of the current articles and at points 5 of Article 29 (Amendmen      5.the sources must be signed during the signing or at the end of the document on ratification, adoption or settlement with the passing of points 2, 6 and 9 of the current articles and at points 5 of Article 29 (Amendment). One way or another, for the parties, it is proposed to issue Part VI (Arbitration) in accordance with Article 18 (resolution on Part VI), after which it was agreed on the terms of the meeting, wy or another, for the parties, it is proposed to issue Part VI (Arbitration) in accordance with Article 18 (resolution on Part VI), after which it was agreed on the terms of the meeting, which were agreed in sub-divisions p), q), r) and s) at Point 1 the articles, which should be taken in the same time, and the implementation of the storehouse deposit in accordance with Article 18 (the decision on the part of Vi).

    6. if the fires were committed during the signing, they should be signed at the request of the document on ratification, adoption or settlement, if only the document, the corresponding fires, does not directly determine that it follows that the relevant ones should be considered with ratification, adoption, adoption, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval, approval.you will receive points 2, 5 and 9 of the current articles and points 5 of 29 (changes).

     7.if the oil and gas industry did not take place during the period of entry, the preliminary contribution of the oil and gas industry should be provided for Depository this time.

     8. for example, in accordance with each of the following terms, words of agreement, in respect of which it was agreed to Part ii) lieutenant A) in point 1 Article 2 (filling of terms), which are provided for in accordance with Article ii according to the law of the Republic of Kazakhstan " on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some there are such lights:

     a) sub-divisions b), c) and d), E) and g) in points 5 Articles 3 (fiscal-prosaic persons);

     b) sub-divisions b), c) and d) in points 3 articles 4 (persons with dual residency);

     c) points 8 and 9 of Article 5 (application of methods for the maintenance of double taxation);

     d) item 4 Article 6 (specific tax agreement, which is announced by the current convention);

     e) sub-divisions b) and c) at point 15 of Article 7 (presumption of harmfulness of claims);

     f) details I), ii) and iii) lieutenant b) Point 3 articles 8 (operations on the transfer of dividends);

     G) sub-branches d), e) and f) in points 6 Articles 9 (income, received in the result of payment of shares or share participation in the person, which form the cost of pre-existing property

     H) subpoenas b) and C) in point 5 of Article 10 (it was proposed to extend the terms of the contracts of post-office representatives, repatriated in third jurisdictions);

     I) lieutenant colonel b) at Point 3 of Article 11 (introduction of tax agreements in order to reduce the number of cases in respect of tax blocking of their residents);

     j) Lieutenant Colonel b) at Point 6 of Article 13 (isual revision of the status of post-representation for inclusion, foreseen for concrete views of activity);

     k) lieutenant b) item 3 of Article 14 (breakdown of contracts);

     l) lieutenant b) at point 5 Article 16 (intramuscular procedure);

     m) lieutenant A) at Point 3 Article 17 (symmetrical corrections);

     n) Item 6 Article 23 (type arbitration procedure); and

     o) item 4 Article 26 (co-operation).

     According to the Ministry of foreign affairs of the Republic of Kazakhstan, this convention is not approved in accordance with the law of the Republic of Kazakhstan "on amendments and additions to some legislative acts of the Republic of Kazakhstan".

     9.a good story, which was given to the fire in accordance with Point 1 or 2, in a good time it is possible to close such a fire or to buy it more than a burnt fire, the direction of the deposit management. Such a story includes additional measures in accordance with Article 6 of 29 (measures), which may involve the introduction of sanctions or the introduction of such measures. With reference point 7 Article 35 (the beginning of the activity) or the beginning of the activity:

     A) in respect of the Tax Agreement, which is published by the current convention, it is necessary to conclude with the state or jurisdiction, which contains the terms of the convention, as well as the amount of money or the amount of money received by the Depositary:

     i) in order to address the issues related to the tax, protected from the East, if the event, which will attract to the tax, will be held first or after the first January of the year, following the establishment of the period of the calendar month, starting from the date of the meeting of the depositary on the reduction of profits or increased emissions); and

     ii) in respect of all other payments, for taxes, paid for the tax period, starting first or after first January of the year, following the establishment of the period of calendar months, starting with the date of the meeting of the Depositary about the reduction or reduction of fires; and

     b) in respect of the Tax Agreement, which is published by the current convention, for which one or another lawful jurisdiction is established by the current convention after the date of receipt of the deposit agreement on receipt or replacement of the deposit: with subsequent ones Danish, with which the existing convention is built on the basis of these specific jurisdictions.

Article 29

     1. with reference to points 5 and 6 of the current articles and points 7 of Article 35 (the beginning of the activity), approved in accordance with the following provisions, should be signed at the time of entry or at the time of entry into force of the document on ratification, adoption or adoption of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of the law on ratification of utverzhdeniy:

     a) Part ii) lieutenant a) point 1 Article 2 (Tolkovanie Termini);

     b) Point 6 Articles 3 (fiscal and prosaic persons);

     c) Point 4 Article 4 (persons with dual residency);

     d) point 10 Article 5 (introduction of methods of two-way rehabilitation);

     e) points 5 and 6 of Article 6 (specific tax agreements, which are distributed to the current meeting);

     f) point 17 Article 7 (presumption of harmfulness of claims);

     g) item 4 Article 8 (operations on the transfer of dividends);

     h) points 7 and 8 Articles 9 (income received as a result of payment of shares or share in the person, which form the cost of pre-existing property);

     i) point 6 of Article 10 (it was approved to discuss the provisions of the tax code of the Republic of Kazakhstan, distributed in third jurisdictions);

     j) item 4 Article 11 (introduction of tax payments in order to reduce the number of cases in respect of tax payments to their residents);

     k) points 5 and 6 of Article 12 (isual revision of the status of post-representation for the consideration of agent agreements and analog strategies);

     l) points 7 and 8 of Article 13 (isual revision of the status of post-presentation for consideration, foreseen for concrete views of activity);

     m) item 4 Article 14 (breakdown of contracts);

     n) Item 6 Article 16 (intramuscular procedure);

     o) item 4 Article 17 (symmetrical corrections);

     p) Article 18 (resolution of Part VI);

     q) item 4 Article 23 (type arbitration procedure);

     r) Item 1 Article 24 (agreement on foreign decisions);

     s) Item 1 Article 26 (co-operation);

     t) Items 1, 2, 3, 5 and 7 of Article 35 (the beginning of activity).

     2. Approval in respect of tax claims, which are declared by the current convention, concluded in jurisdictions or territories or from their representatives, for international relations of which there is no responsibility, if such jurisdiction or territory does not have a story meeting with Lieutenant Colonel B) or C) at Point 1 of Article 27 (entry and ratification, adoption or settlement), should be responsible for the meeting and can be removed from the agreement, provided this meeting for their negative opinions, which are the current convention is announced.

     3. if the agreement was signed during the signing, they should be signed at the request of the document on ratification, adoption or settlement, if only the document, the binding agreement, does not determine that it follows it is important to note that points 5 and 6 present articles and points 7 Article 35 (the beginning of the activity).

     4.if the implementation did not take place during the period of entry, a preliminary statement should be provided in this time.

     5.at a good time, it is possible to expand the scope of agreements, in respect of which the agreement is made with Part II) lieutenant A) in point 1 Article 2 (terms and conditions), under the direction of the depositary administration. In addition, the report says that there is an agreement between the number of people who have been killed, transferred to 8 points of Article 28 (fires). It is also possible to create a new fire station, provided in 8 articles 28 (fire stations), if a further agreement will be made first, which will be provided by such fire stations. The report also emphasizes the need for additional measures, which can be applied in accordance with sub-divisions with B) to s) at Point 1 with the purpose of adding additional agreements. In addition, if the expansion of access to the tax code, the concluded jurisdiction or the territory or from their owners, for international relations, which are subject to responsibility, the number of loved ones is determined (according to point 4 of the Article 28 (lights)) or approval (according to point 2 of the current article), which are declared by the current convention, which is signed by such jurisdiction or territory or from their owners. According to the date, C added agreement(I), in respect of which it was agreed to in accordance with Part ii) lieutenant A) in point 1 Article 2 (terms), there are negative agreements, which are published by the current convention, articles 35 (the date is determined, with which it will be possible to change the number of negative opinions, which are published by the current convention.

     6.It is possible to make additional payments in accordance with sub-divisions with B) to s) at Point 1, depending on the deposit payment. This is how we start to act:

     A) in respect of tax agreements, which are issued by the current convention, including with the state or jurisdiction, the parties involved in the convention, receiving additional payment of depositories:

A) in respect of tax agreements, which are issued by the current convention, including with the state or jurisdiction, the parties involved in the convention, receiving additional payment of depositories:

     i) for payment in terms of payments, related to taxes, dependent on the state, if the conditions/events, which are taken to raise such taxes, arise with first or after January 1, following the establishment of the border calendar months, starting with the date of the meeting of the depositary on additional settlement; and

     ii) to ensure compliance in respect of all other fields, connected with the tax, associated with the tax period, starting first or after the first January of the year, following the dates of the calendar month, starting with the date of the meeting depository of the Republic of Kazakhstan;  

     b) in respect of tax agreements, which are published by the current convention, for which one or more relevant jurisdictions are established by the Convention on the receipt of deposits by the Danish Depository: with subsequent ones from the Danish, with the subsequent ones from the Danish, with the subsequent ones from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the latter from the Danish, with the convention is built on the basis of these specific jurisdictions.

Article 30 - recent changes in tax legislation, which are announced by the current convention

     There is no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such convention, no such Convention.

Article 31-Storon Conference

     1.the parties can create a conference for the adoption of some-libo decisions or the adoption of some-libo functions, which can be applied or be focused on the main provisions of the current convention.

     2. The Conference meeting is provided by The Depository.

     3.A Loving Story can be held at the conference, which is aimed at depositing funds. The depository informs about all the stories of love. This depository will hold a conference session under the conditions that will support one third session in the period of calendar months after the administration of the depository.

Article 32-Tolkovanie and priming

     1. the question of Love, rising at the meeting or at the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the second meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the first meeting of the the current convention, connected with the conclusion of a mutual agreement on the issues of toleration or the introduction of a negative agreement, is announced at the current convention (as such changes may be made to the current convention).

     2.A Love Other issue, which arises at the meeting or at the meeting, can be considered at the conference meeting, created in accordance with paragraph 3 of Article 31 (Conference meeting).

Article 33 - introduction of popravok

     1.it is possible to propose the introduction of a deposit to the current meeting after the presentation of the proposed deposit deposit.

     2. The Conference Report can be created for consideration of proposed amendments in accordance with paragraph 3 of Article 31 (Conference Report).

Article 34-insertion in the face

     1. This Convention shall enter into force on the first day of the month following the expiration of a period of three calendar months from the date of deposit of the fifth instrument of ratification, acceptance or approval.

     2. for every sign, ratification, adoption or approval of the current convention, after approval of the fifth instrument of ratification, adoption or approval, the current convention is included in the line with the first day of the month, following the establishment of the period of three calendar months, starting with the date of receipt of such a report on its ratification, adoption or repayment.

Article 35 - the beginning of activity

     1. Approval of the current convention will be applied in every jurisdiction in respect of the Tax Agreement, which is published by the current convention:

     a) in respect of nalogov, employed by the east, to the summaries, issued or transferred non-residents, if events, which involve such nalogam, pass the first or after the first day of the following calendar year, which begin with the date or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the first day of the current calendar year, or the date of the current calendar year, or the date of the first day of the current calendar year, or the date of the current calendar year, or the date of the current calendar year, or the date of the current calendar year, or the date of the current calendar year, or the date of the current calendar year, or the date of the current calendar year, or the date of the current calendar year. last year from Denmark, with the current convention, there is a line for every jurisdiction that determines the right of the current convention; and

     b) in respect of all other nalogov, it is determined by the jurisdiction, for nalogov, taking into account the tax period, starting with or after the establishment of the period of calendar months (or more short period, if all according to the law of the Republic of Kazakhstan "on amendments and additions to some legislative acts of the Republic of Kazakhstan", it should be noted that the law of the Republic of Kazakhstan " on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some legislative acts of the Republic of Kazakhstan on amendments and additions to some the current convention is announced.

     2.it is necessary to take into account the decision of the "calendar year" on the "tax period" and the established order of the deposit.

     3. it is also necessary to take into account the decision on the introduction of a "negative period", starting with or after the establishment of a "negative period", starting with the first or after the first period.first January of the next year, starting with or after the establishment of the period "" and in accordance with the established order, the Depositary will be saved."

     4. It is necessary to take into account the previous provisions of the current article, Article 16 (comprehensive procedure) is applied in relation to the Tax Agreement, which is published by the current convention, to apply to the represented competent authority, which determines the jurisdiction with or without last year from Denmark, with the current convention, there is a line for each of the relevant jurisdictions of the tax code, which is published by the current convention, which does not have the right to be represented in this country compliance with the tax code, the current convention, until its change in accordance with the current convention, is not possible from the negative period, for which the application is made.

     5. for a new tax agreement, which is announced at the current convention, the introduction of amendments to paragraph 5 of Article 29, according to which Part ii) lieutenant A) in point 1 of Article 2 (toleration of terms) the transfer of the existing convention is imposed in every lawful jurisdiction:

     a) in respect of nalogov, employed by easterners, to the summaries, issued or transferred non-residents, if any, which are granted to such nalogov, will be held with first or after 30 days after the date of the meeting of the Depository on the expansion of the spiska soglasheny; I

     b) in respect of all other nalogs, related to this jurisdiction, to nalogs, related to the tax period, starting with or after the establishment of the period of development of calendar months (or more short period, if all related periods the jurisdiction of the depository on its name to take into account such a rather short period) with the date of the meeting of the depository on the extension of the agreement.

     6.It is possible to maintain the right to do so, but not to take into account Point 4 in relation to their negative opinions, which are published by the current convention.

     7. a) The Story can stay for so much more:

     i) "The Last Days of Denmark, with which the current convention is built on the basis of every jurisdiction that determines the current convention"; and

     ii)losses in point 5 on the "date of the meeting of the Depositary on the expansion of the agreement";

     "30 days after the date of receipt of the deposit of the last one from the relevant jurisdiction, the current one, issued in 7 Articles 35 (the beginning of the activity) about the completion of the internal procedure for the beginning of the activity of the deposit the current convention in respect of such specific tax agreements, which is announced by the current convention";

     iii) letters to the Lieutenant Colonel A) in Point 9 of Article 28 (articles) "with the date of the meeting of the Depositary on payment of profits or changes in taxes"; and

     iv) to issue in subprime B) Point 9 of Article 28 "from the past of Denmark, with which the current convention is built on the basis of certain jurisdictions";

     "30 days after the date of receipt of the deposit from the last one of the determining jurisdictions, the operating authority, approved in point 7 Article 35 (the beginning of the activity) on the completion of the internal procedure for the beginning of the activity of the snytiya or the increase lights in relation to this specific tax agreement, which is announced by the current convention";

     v) letters to the Lieutenant Colonel A) at Point 6 of Article 29 (settlement) on "with the date of the meeting of the Depository on additional settlement"; and

     vi) to the Lieutenant Colonel b) Point 6 of Article 29 (articles) on "from the past of Denmark, with which the current convention applies to certain jurisdictions";

"30 days after the date of receipt of the deposit of the last one from the relevant jurisdiction, which is authorized in point 7 of Article 35 (the beginning of the introduction) on the implementation of the internal procedure for the beginning of the activity of the deposit the current convention in respect of such specific tax agreements is announced by the current convention"; and

     viii) Article 36 (the beginning of the Chapter VI) on the "date of the meeting of the Depositary on the expansion of the agreement";

     ix) Articles 4 in 36 points (the beginning of the Chapter VI) on the "date of the meeting of the Depositary on payment of expenses"; and

     x) Article 36 of 5 (the beginning of the Chapter VI) on the date of the meeting of the Depositary on additional settlement ";

     "30 days after the date of receipt of the deposit of the last one from the relevant jurisdiction, which is authorized in point 7 of Article 35 (the beginning of the activity) about the introduction of internal procedures for the introduction of a part of the line VI (arbitration) in respect of such specific tax agreements, which are published by the current convention".

     b) the report, which is carried out by the head of State in accordance with the sub-lieutenant a), establishes in compliance with the internal procedure, which is aimed at single Depositary and other related jurisdictions (jurisdictions).

     C) if one or another law enforcement jurisdiction, which is published by the current convention, the date of the beginning of the convention, the date of the date of the meeting, the date of the date of the meeting, the date of the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting, the date of the meeting in respect of this tax agreement, which is published by the current convention, or Part VI (arbitration), it is determined by the current point for all the relevant jurisdictions of the Tax Agreement, which is published by the current convention.

Article 36 - beginning of activity Part VI

     1. it is impossible to say at points 9 of Article 28 (lights), at points 6 of Article 29 (lights) and points 1 to 6 of Article 35 (the beginning of the activity), in respect of two specific jurisdictions, which are represented by the current convention Part VI (arbitration) begins to act:

     a) in respect of applications submitted by the competent authority to determine the jurisdiction (as stated in the subparagraph A) in Paragraph 1 of Article 19 (mandatory for the execution of the arbitration resolution), with or after the date of the current convention is included in the silhouette is for each of those jurisdictions that are subject to the current convention; and

     b) in respect of applications submitted to the Competent Authority of the relevant jurisdiction until the end of the year from Denmark, with which the current convention applies to each of the relevant jurisdictions of the tax code, which is published the current convention, in Denmark, with the relevant jurisdiction, has passed Depositary agreements on compliance with Paragraph 10 of Article 19 (mandatory for execution of Arbitration resolution) with the decree of the president of the Republic of Kazakhstan, with such an application, it is considered that the represented competent body of the governing jurisdiction (as stated in the subparagraph A) has 1 Article 19 (mandatory for the execution of the arbitration resolution) in accordance with the terms of such mutual agreement.

     2. the meeting can be held by the law on the priority of Part VI (arbitration) to appeal, represented by a competent authority of the relevant jurisdiction until the end of the year from Denmark, with which the current convention is based on each of the relevant jurisdictions tax compliance, which is announced at the current convention, only to the wedding, in which the competent authorities of the relevant jurisdictions agree, that this law will be applied to such specific applications.

     3. In the speech of the new tax agreement, which is published in accordance with the current convention, the introduction of amendments to paragraph 5 of Article 29, according to which Part ii) lieutenant A) in point 1 of Article 2 (the toleration of terms) "in points 1 and 2, the current articles on ""last year from Denmark, with which the current convention is built on the basis of each of the relevant jurisdictions of the tax code", "the current convention ""is imposed on the date of the meeting of the Depositary on the expansion of the agreement""."

     4. Sign or sign, drawn up in accordance with Point 4 Article 26, point 9 Article 28, point 9 Article 28, point 2 Article 28, point 2 Article 28, which is subject to the introduction of Part VI (arbitration) between two judicial acts, which are published by the current convention, will be applied in accordance with the terms of A) and B) at Point 1 of the article, for the exclusion of the last days of Denmark, "with the current convention, there is a line for every jurisdiction that determines the right of tax consideration, the current convention "" is imposed on the risks of "" meeting of the Depositary on the reduction of the number of fires"", ""meeting of the Daniyar"". ""the depositary on increasing the number of fires ""or the date of the meeting of the Depositary on increasing the number of fires "" accordingly."

     5. additional improvement, according to the Lieutenant Colonel P) at Point 1 Article 29 (improvement), which is applied in accordance with the sub-lieutenants a) and B) at Point 1, for inclusion, when missing in points 1 and 2 of the current article "last year from Denmark, with which the current convention is built on the basis of one of the most relevant jurisdictions of the tax code, which is published by the current convention" imposed sanctions on the date of the depositary agreement".

 Article 37-Denunciation

     1.a good story in a good time can denounce the current meeting of the Depositary administration.

     2.denunciation in accordance with Point 1 begins to act with the date of receipt of depositary payments. At the same time, if the current convention begins to refer to all relevant jurisdictions, which are published by the current convention, with which the denunciation of the convention, such a negative agreement, to which it is issued, it will be published in the form of a judicial convention, such a negative agreement, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention, such a convention the current convention is announced, and the current convention is held in the vide.

     Article 38-interaction with protocols

     1.the current convention can be supplemented by one or another protocol.

     2.to be included in the protocol, the state or jurisdiction should also be a regular meeting.

     3.the date of the meeting is not related to the protocol, if only it is not established by such protocol in accordance with its requirements.

Article 39-Depository

     1.the general secretary of the Organization of Economic Cooperation and development of the Depository has the right to Convocation and love protocols in accordance with Article 38.

     2. The Depository on the date of the single calendar month will increase the number of accounts and the number of entries:

     a) I love to sign in accordance with Article 27 (signing and ratification, adoption or repayment);

     b)the agreement on ratification, adoption or termination in accordance with Article 27 (entry and ratification, adoption or termination);

     c) lover of Fire, profit or loss in accordance with Article 28 (fire);

     d) on the love of education or additional education in accordance with Article 29 (Education);

     e) love for the proposed meeting in accordance with Article 33;

     f) love denunciation of the present Convention in accordance with Article 37 (denunciation); and

     g) love other connected with the present Meeting of the meeting.

     3. The Depository shall provide public services:

     a) negative opinions, which are published by the current convention;

     b) fireboxes, hidden storerooms; and

     (C) the number of people involved.

     At the end of the meeting, the necessary image for the general meeting was signed.

     In Paris, on November 24, 2016, in English and French languages, the text of the plague has a single silhouette, a single example, which is located in the archive of the Organization of Economic Cooperation and development.

     It is noted that the text received is a full copy of numerous meetings on the issue of goods, related to tax agreements, in order to increase the tax base and output from the tax code, signed in Paris on November 24, 2016, the original will be addressed to the General Secretary of the organization of Economic Cooperation and development.

     Paris, July 5, 2018

     General secretary,

      Director on legal issues  

      Nicola Bonuci  

     I confirm that the text of the multilateral convention in Kazakh on the implementation of measures related to tax agreements in order to counteract the disguising of the tax base and the withdrawal of profits from taxation corresponds to the text in the original language.

     Head of the document editing and Linguistics Examination Department of the Document Management Department of the Ministry of Finance of the Republic of Kazakhstan

B. M. Akhmetzhanova

     I nodded.         The text of the Convention in English and French is attached.

President    

Republic of Kazakhstan     

© 2012. RSE na PHB "Institute of Legislation and Legal Information of the Republic of Kazakhstan" of the Ministry of Justice of the Republic of Kazakhstan  

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