30. pants

DARBĪBAS IZBEIGŠANA

1. Šis Līgums ir spēkā, līdz Līgumslēdzēja Valsts izbeidz tā

darbību. Katra Līgumslēdzēja Valsts var izbeigt Līguma darbību,

pēc 5 (piecu) gadu perioda no šī Līguma spēkā stāšanās datuma

beigām, pa diplomātiskajiem kanāliem iesniedzot rakstisku

paziņojumu par izbeigšanu vismaz 6 (sešus) mēnešus pirms jebkura

kalendārā gada, kas seko minētajam periodam, beigām.

2. Šī Līguma darbība abās Līgumslēdzējās Valstīs tiek

izbeigta:

a) attiecībā uz nodokļiem, ko ietur ienākuma izmaksas brīdī

par samaksātajām vai ieskaitītajām summām, kas gūtas janvāra

pirmajā dienā vai pēc tās, kalendārajā gadā, kas seko gadam, kurā

ir iesniegts paziņojums; un

b) attiecībā uz pārējiem nodokļiem, kas maksājami par jebkuru

taksācijas gadu, kas sākas janvāra pirmajā dienā vai pēc tās,

kalendārajā gadā, kas seko gadam, kurā iesniegts paziņojums.

To apliecinot, būdami pienācīgi pilnvaroti, šo Līgumu ir

parakstījuši.

Sastādīts Ņujorkā divos eksemplāros 2014.gada 26.septembrī,

katrs latviešu, arābu un angļu valodā, turklāt visi teksti ir

vienlīdz autentiski. Atšķirīgas interpretācijas gadījumā

noteicošais ir teksts angļu valodā.

Latvijas Republikas

valdības vārdā

Edgars Rinkēvičs

Ārlietu ministrs

Kataras Valsts

valdības vārdā

Ahmeds bin Jasims Al Thani

Ekonomikas

ministrs

AGREEMENT BETWEEN THE GOVERNMENT

OF THE REPUBLIC OF LATVIA

AND THE GOVERNMENT OF THE STATE OF QATAR

FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION

OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

The Government of the Republic of Latvia and the Government of

the State of Qatar,

Desiring to conclude an Agreement for the Avoidance of Double

Taxation and the Prevention of Fiscal Evasion with Respect to

Taxes on Income,

Have agreed as follows:

Article 1

PERSONS COVERED

This Agreement shall apply to persons who are residents of one

or both of the Contracting States.

Article 2

TAXES COVERED

1. This Agreement shall apply to taxes on income imposed on

behalf of a Contracting State or of its political subdivisions or

local authorities, irrespective of the manner in which they are

levied.

2. There shall be regarded as taxes on income all taxes

imposed on total income or on elements of income, including taxes

on gains from the alienation of movable or immovable

property.

3. The existing taxes to which the Agreement shall apply are

in particular:

a) in the case of the Republic of Latvia:

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

and

(ii) the personal income tax (iedzivotaju ienakuma

nodoklis);

(hereinafter referred to as "Latvian tax"); and

b) in the case of the State of Qatar:

(i) taxes on income;

(hereinafter referred to as "Qatari tax").

4. The Agreement shall apply also to any identical or

substantially similar taxes that are imposed after the date of

signature of the Agreement in addition to, or in place of, the

existing taxes. The competent authorities of the Contracting

States shall notify each other of any significant changes that

have been made in their taxation laws.

Article 3

GENERAL DEFINITIONS

1. For the purposes of this Agreement, unless the context

otherwise requires:

a) the term "Latvia" means the Republic of Latvia

and, when used in the geographical sense, means the territory of

the Republic of Latvia and any other area adjacent to the

territorial waters of the Republic of Latvia within which under

the laws of Latvia and in accordance with international law, the

rights of Latvia may be exercised with respect to the sea bed and

its sub-soil and their natural resources;

b) the term "Qatar" means, the State of Qatar and,

when used in the geographical sense, means the State of

Qatar's lands, internal waters, territorial sea including its

bed and sub soil, the air space over them, the exclusive economic

zone and the continental shelf, over which the State of Qatar

exercises sovereign rights and jurisdiction in accordance with

the provisions of international law and Qatar's national laws

and regulations;

c) the terms "a Contracting State" and "the

other Contracting State" mean Latvia or Qatar, as the

context requires;

d) the term "person" includes an individual, a

company and any other body of persons;

e) the term "company" means any body corporate or

any entity which is treated as a body corporate for tax

purposes;

f) the terms "enterprise of a Contracting State" and

"enterprise of the other Contracting State" mean

respectively an enterprise carried on by a resident of a

Contracting State and an enterprise carried on by a resident of

the other Contracting State;

g) the term "international traffic" means any

transport by a ship or aircraft operated by an enterprise of a

Contracting State, except when the ship or aircraft is operated

solely between places in the other Contracting State;

h) the term "competent authority" means:

(i) in the case of Latvia, the Ministry of Finance or its

authorised representative, and

(ii) in the case of Qatar, the Ministry of Finance, or its

authorized representative;

i) the term "national" in relation of a Contracting

State means:

(i) any individual possessing the nationality of a Contracting

State;

(ii) any legal person, partnership or association deriving its

status as such from the laws in force in that Contracting

State.

2. As regards the application of the Agreement at any time by

a Contracting State, any term not defined therein shall, unless

the context otherwise requires, have the meaning that it has at

that time under the law of that State for the purposes of the

taxes to which the Agreement applies, any meaning under the

applicable tax laws of that State prevailing over a meaning given

to the term under other laws of that State.

Article 4

RESIDENT

1. For the purposes of this Agreement, the term "resident

of a Contracting State" means:

a) in the case of Latvia, any person who, under the laws of

Latvia, is liable to tax therein by reason of his domicile,

residence, place of management, place of incorporation or any

other criterion of a similar nature, and also includes the

Republic of Latvia and any local authority or statutory body

thereof. This term, however, does not include any person who is

liable to tax in Latvia in respect only of income from sources in

Latvia;

b) in the case of Qatar, any individual who has a permanent

home, his centre of vital interest, or habitual abode in Qatar,

and a company incorporated in Qatar. The term also includes the

State of Qatar and any political subdivision, local authority or

statutory body thereof.

2. Where by reason of the provisions of paragraph 1 an

individual is a resident of both Contracting States, then his

status shall be determined as follows:

a) he shall be deemed to be a resident only of the State in

which he has a permanent home available to him; if he has a

permanent home available to him in both States, he shall be

deemed to be a resident only of the State with which his personal

and economic relations are closer (centre of vital

interests);

b) if the State in which he has his centre of vital interests

cannot be determined, or if he has not a permanent home available

to him in either State, he shall be deemed to be a resident only

of the State in which he has an habitual abode;

c) if he has an habitual abode in both States or in neither of

them, he shall be deemed to be a resident only of the State of

which he is a national;

d) if the residence status of an individual cannot be

determined in accordance with the provisions of subparagraphs a),

b) and c) above, the competent authorities of the Contracting

States shall settle the question by mutual agreement.

3. Where by reason of the provisions of paragraph 1 a person

other than an individual is a resident of both Contracting

States, the competent authorities of the Contracting States shall

endeavour to settle the question by mutual agreement.

Article 5

PERMANENT ESTABLISHMENT

1. For the purposes of this Agreement, the term

"permanent establishment" means a fixed place of

business through which the business of an enterprise is wholly or

partly carried on.

2. The term "permanent establishment" includes

especially:

a) a place of management;

b) a branch;

c) an office;

d) a factory;

e) a workshop;

f) premises used as sales outlet;

g) a farm or plantation, and

h) a mine, an oil or gas well, a quarry or any other place of

exploration, extraction or exploitation of natural resources.

3. The term "permanent establishment" also

encompasses:

a) a building site, a construction, assembly or installation

project or any supervisory activity in connection with such site

or project, but only where such site, project or activity

continues for a period or periods aggregating more than 6 (six)

months within any 12 (twelve) month period; and

b) the furnishing of services, including consultancy services,

by an enterprise through employees or other personnel engaged by

the enterprise for such purpose, but only if the activities of

that nature continue (for the same or a connected project) within

a Contracting State for period or periods aggregating more than 6

(six) months within any 12 (twelve) month period.

4. Notwithstanding the preceding provisions of this Article,

the term "permanent establishment" shall be deemed not

to include:

a) the use of facilities solely for the purpose of

storage, display or delivery of goods or merchandise

belonging to the enterprise;

b) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of storage,

display or delivery;

c) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of processing

by another enterprise;

d) the maintenance of a fixed place of business solely for the

purpose of purchasing goods or merchandise or of collecting

information, for the enterprise;

e) the maintenance of a fixed place of business solely for the

purpose of carrying on, for the enterprise, any other activity of

a preparatory or auxiliary character;

f) the maintenance of a fixed place of business solely for any

combination of activities mentioned in sub paragraphs a) to e),

provided that the overall activity of the fixed place of business

resulting from this combination is of a preparatory or auxiliary

character.

5. Notwithstanding the provisions of paragraphs 1 and 2, where

a person - other than an agent of an independent status to whom

paragraph 6 applies - is acting on behalf of an enterprise and

has, and habitually exercises, in a Contracting State an

authority to conclude contracts in the name of the enterprise,

that enterprise shall be deemed to have a permanent establishment

in that State in respect of any activities which that person

undertakes for the enterprise, unless the activities of such

person are limited to those mentioned in paragraph 4 which, if

exercised through a fixed place of business, would not make this

fixed place of business a permanent establishment under the

provisions of that paragraph.

6. An enterprise shall not be deemed to have a permanent

establishment in a Contracting State merely because it carries on

business in that State through a broker, general commission agent

or any other agent of an independent status, provided that such

persons are acting in the ordinary course of their business.

However, when the activities of such an agent are devoted wholly

or almost wholly on behalf of that enterprise, and conditions are

made or imposed between that enterprise and the agent in their

commercial and financial relations which differ from those which

would have been made between independent enterprises, he will not

be considered an agent of an independent status within the

meaning of this paragraph.

7. The fact that a company which is a resident of a

Contracting State controls or is controlled by a company which is

a resident of the other Contracting State, or which carries on

business in that other State (whether through a permanent

establishment or otherwise), shall not of itself constitute

either company a permanent establishment of the other.

Article 6

INCOME FROM IMMOVABLE PROPERTY

1. Income derived by a resident of a Contracting State from

immovable property (including income from agriculture or

forestry) situated in the other Contracting State may be taxed in

that other State.

2. The term "immovable property" shall have the

meaning which it has under the law of the Contracting State in

which the property in question is situated. The term shall in any

case include property accessory to immovable property, livestock

and equipment used in agriculture and forestry, rights to which

the provisions of general law respecting landed property apply,

any option or similar right in relation to immovable property,

usufruct of immovable property and rights to variable or fixed

payments as consideration for the working of, or the right to

work, mineral deposits, sources and other natural

resources. Ships and aircraft shall not be regarded as

immovable property.

3. The provisions of paragraph 1 shall apply to income derived

from the direct use, letting, or use in any other form of

immovable property, as well as income from the alienation

of immovable property.

4. Where the ownership of shares or other corporate rights in

a company entitles the owner of such shares or corporate rights

to the enjoyment of immovable property held by the company, the

income from the direct use, letting, or use in any other form of

such right to enjoyment may be taxed in the Contracting State in

which the immovable property is situated.

5. The provisions of paragraphs 1, 3 and 4 shall also

apply to the income from immovable property of an enterprise and

to income from immovable property used for the performance of

independent personal services.

Article 7

BUSINESS PROFITS

1. The profits of an enterprise of a Contracting State shall

be taxable only in that State unless the enterprise carries on

business in the other Contracting State through a permanent

establishment situated therein. If the enterprise carries on

business as aforesaid, the profits of the enterprise may be taxed

in the other State but only so much of them as is attributable to

that permanent establishment.

2. Subject to the provisions of paragraph 3, where an

enterprise of a Contracting State carries on business in the

other Contracting State through a permanent establishment

situated therein, there shall in each Contracting State be

attributed to that permanent establishment the profits which it

might be expected to make if it were a distinct and separate

enterprise engaged in the same or similar activities under the

same or similar conditions and dealing wholly independently with

the enterprise of which it is a permanent establishment.

3. In determining the profits of a permanent establishment in

a Contracting State, there shall be allowed as deductions

expenses which are incurred for the purposes of the permanent

establishment, including executive and general administrative

expenses so incurred, whether in the State in which the permanent

establishment is situated or elsewhere, which are allowed under

the provisions of the domestic law of the Contracting State in

which the permanent establishment is situated.

4. Insofar as it has been customary in a Contracting State to

determine the profits to be attributed to a permanent

establishment on the basis of an apportionment of the total

profits of the enterprise to its various parts, nothing in

paragraph 2 shall preclude that Contracting State from

determining the profits to be taxed by such an apportionment as

may be customary; the method of apportionment adopted shall,

however, be such that the result shall be in accordance with the

principles contained in this Article.

5. No profits shall be attributed to a permanent establishment

by reason of the mere purchase by that permanent establishment of

goods or merchandise for the enterprise.

6. For the purposes of the preceding paragraphs, the profits

to be attributed to the permanent establishment shall be

determined by the same method year by year unless there is good

and sufficient reason to the contrary.

7. Where profits include items of income which are dealt with

separately in other Articles of this Agreement, then the

provisions of those Articles shall not be affected by the

provisions of this Article.

Article 8

SHIPPING AND AIR TRANSPORT

1. Profits of an enterprise of a Contracting State from the

operation of ships or aircraft in international traffic shall be

taxable only in that State.

2. For the purposes of this Article, profits of an enterprise

from the operation of ships or aircraft in international traffic

include:

a) profits from the rental on a bareboat basis of ships or

aircraft; and

b) profits from the use, maintenance or rental of containers

(including trailers and related equipment for the transport of

containers) used for the transport of goods or merchandise;

where such rental or such use, maintenance or rental, as the

case may be, is incidental to the operation of ships or aircraft

by the enterprise in international traffic.

3. The provisions of paragraph 1 shall also apply to profits

from the participation in a pool, a joint business or an

international operating agency.

Article 9

ASSOCIATED ENTERPRISES

1. Where

a) an enterprise of a Contracting State participates directly

or indirectly in the management, control or capital of an

enterprise of the other Contracting State, or

b) the same persons participate directly or indirectly in the

management, control or capital of an enterprise of a Contracting

State and an enterprise of the other Contracting State,

and in either case conditions are made or imposed between the

two enterprises in their commercial or financial relations which

differ from those which would be made between independent

enterprises, then any profits which would, but for those

conditions, have accrued to one of the enterprises, but, by

reason of those conditions, have not so accrued, may be included

in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an

enterprise of that State - and taxes accordingly - profits on

which an enterprise of the other Contracting State has been

charged to tax in that other State and the profits so included

are profits which would have accrued to the enterprise of the

first-mentioned State if the conditions made between the two

enterprises had been those which would have been made between

independent enterprises, then that other State shall make an

appropriate adjustment to the amount of the tax charged therein

on those profits if it agrees with the adjustment made by the

first-mentioned State. In determining such adjustment, due regard

shall be had to the other provisions of this Agreement and the

competent authorities of the Contracting States shall if

necessary consult each other.

Article 10

DIVIDENDS

1. Dividends paid by a company which is a resident of a

Contracting State to a resident of the other Contracting State

may be taxed in that other State.

2. However, such dividends may also be taxed in the

Contracting State of which the company paying the dividends is a

resident and according to the laws of that State, but if the

beneficial owner of the dividends is a resident of the other

Contracting State, the tax so charged shall not exceed:

a) 0 (zero) per cent of the gross amount of the dividends if

the beneficial owner is a company (other than a partnership);

b) 5 (five) per cent of the gross amount of the dividends in

all other cases.

This paragraph shall not affect the taxation of the company in

respect of the profits out of which the dividends are paid.

3. Notwithstanding the provisions of subparagraph b) of

paragraph 2, dividends referred to in paragraph 1 shall be

taxable only in the Contracting State in which the beneficial

owner is a resident if:

a) the beneficial owner is a Contracting State, a political

subdivision, a local authority, a statutory body or the Central

Bank thereof;

b) in the case of Latvia, the beneficial owner is one of the

following entities:

(i) the Latvian Guarantee Agency;

(ii) any other institution, as may be agreed from time to time

between the competent authorities of the Contracting States;

c) in the case of Qatar, the beneficial owner is one of the

following entities as long as they are wholly owned by Qatar:

(i) Qatar Investment Authority;

(ii) Qatar Holding,

(iii) Qatar Retirement Funds,

(iv) Qatar Development Bank, and

(v) any other institution, as may be agreed from time to time

between the competent authorities of the Contracting States.

4. The term "dividends" as used in this Article

means income from shares or other rights, not being debt-claims,

participating in profits, as well as income from other corporate

rights which is subjected to the same taxation treatment as

income from shares by the laws of the State of which the company

making the distribution is a resident.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if

the beneficial owner of the dividends, being a resident of a

Contracting State, carries on business in the other Contracting

State of which the company paying the dividends is a resident,

through a permanent establishment situated therein, or performs

in that other State independent personal services from a fixed

base situated therein, and the holding in respect of which the

dividends are paid is effectively connected with such permanent

establishment or fixed base. In such case the provisions of

Article 7 or Article 14, as the case may be, shall apply.

6. Where a company which is a resident of a Contracting State

derives profits or income from the other Contracting State, that

other State may not impose any tax on the dividends paid by the

company, except insofar as such dividends are paid to a resident

of that other State or insofar as the holding in respect of which

the dividends are paid is effectively connected with a permanent

establishment or a fixed base situated in that other State, nor

subject the company's undistributed profits to a tax on the

company's undistributed profits, even if the dividends paid

or the undistributed profits consist wholly or partly of profits

or income arising in such other State.

Article 11

INTEREST

1. Interest arising in a Contracting State and paid to a

resident of the other Contracting State may be taxed in that

other State.

2. However, such interest may also be taxed in the Contracting

State in which it arises and according to the laws of that State,

but if the beneficial owner of the interest is a resident of the

other Contracting State, the tax so charged shall not exceed:

a) 0 (zero) per cent of the gross amount of the interest if

the beneficial owner is a company (other than a partnership);

b) 5 (five) per cent of the gross amount of the interest in

all other cases.

3. Notwithstanding the provisions of paragraph 2, interest

referred to in paragraph 1 shall be taxable only in the

Contracting State in which the beneficial owner is a resident

if:

a) the beneficial owner is a Contracting State, a political

subdivision, a local authority, a statutory body or the Central

Bank thereof;

b) in the case of Latvia, the beneficial owner is one of the

following entities:

(i) the Latvian Guarantee Agency;

(ii) any other institution, as may be agreed from time to time

between the competent authorities of the Contracting States;

c) in the case of Qatar, the beneficial owner is one of the

following entities as long as they are wholly owned by Qatar:

(i) Qatar Investment Authority;

(ii) Qatar Holding;

(iii) Qatar Retirement Funds;

(iv) Qatar Development Bank; and

(v) any other institution, as may be agreed from time to time

between the competent authorities of the Contracting States.

4. The term "interest" as used in this Article means

income from debt-claims of every kind, whether or not secured by

mortgage and whether or not carrying a right to participate in

the debtor's profits, and in particular, income from government

securities and income from bonds or debentures, including

premiums and prizes attaching to such securities, bonds or

debentures. The term "interest" shall not include any

income which is treated as a dividend under the provisions of

paragraph 4 of Article 10. Penalty charges for late payment shall

not be regarded as interest for the purpose of this Article.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if

the beneficial owner of the interest, being a resident of a

Contracting State, carries on business in the other Contracting

State in which the interest arises, through a permanent

establishment situated therein, or performs in that other State

independent personal services from a fixed base situated therein,

and the debt-claim in respect of which the interest is paid is

effectively connected with such permanent establishment or fixed

base. In such case the provisions of Article 7 or Article 14, as

the case may be, shall apply.

6. Interest shall be deemed to arise in a Contracting State

when the payer is a resident of that State. Where, however, the

person paying the interest, whether he is a resident of a

Contracting State or not, has in a Contracting State a permanent

establishment or a fixed base in connection with which the

indebtedness on which the interest is paid was incurred, and such

interest is borne by such permanent establishment or fixed base,

then such interest shall be deemed to arise in the State in which

the permanent establishment or fixed base is situated.

7. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the interest, having regard to the

debt-claim for which it is paid, exceeds the amount which would

have been agreed upon by the payer and the beneficial owner in

the absence of such relationship, the provisions of this Article

shall apply only to the last-mentioned amount. In such case, the

excess part of the payments shall remain taxable according to the

laws of each Contracting State, due regard being had to the other

provisions of this Agreement.

Article 12

ROYALTIES

1. Royalties arising in a Contracting State and paid to a

resident of the other Contracting State may be taxed in that

other State.

2. However, such royalties may also be taxed in the

Contracting State in which they arise and according to the laws

of that State, but if the beneficial owner of the royalties is a

resident of the other Contracting State, the tax so charged shall

not exceed 5 (five) per cent of the gross amount of the

royalties.

3. The term "royalties" as used in this Article

means payments of any kind received as a consideration for the

use of, or the right to use, any copyright of literary, artistic

or scientific work including cinematograph films and

films, tapes or discs for radio or television

broadcasting, any patent, trade mark, design or model, plan,

secret formula or process, or for the use of, or the right to

use, industrial, commercial or scientific equipment, or

for information concerning industrial, commercial or scientific

experience.

4. The provisions of paragraphs 1 and 2 shall not apply if the

beneficial owner of the royalties, being a resident of a

Contracting State, carries on business in the other Contracting

State in which the royalties arise, through a permanent

establishment situated therein, or performs in that other State

independent personal services from a fixed base situated therein,

and the right or property in respect of which the royalties are

paid is effectively connected with such permanent establishment

or fixed base. In such case the provisions of Article 7 or

Article 14, as the case may be, shall apply.

5. Royalties shall be deemed to arise in a Contracting State

when the payer is a resident of that State. Where, however, the

person paying the royalties, whether he is a resident of a

Contracting State or not, has in a Contracting State a permanent

establishment or a fixed base in connection with which the

liability to pay the royalties was incurred, and such royalties

are borne by such permanent establishment or fixed base, then

such royalties shall be deemed to arise in the State in which the

permanent establishment or fixed base is situated.

6. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the royalties, having regard to the

use, right or information for which they are paid, exceeds the

amount which would have been agreed upon by the payer and the

beneficial owner in the absence of such relationship, the

provisions of this Article shall apply only to the last-mentioned

amount. In such case, the excess part of the payments shall

remain taxable according to the laws of each Contracting State,

due regard being had to the other provisions of this

Agreement.

Article 13

CAPITAL GAINS

1. Gains derived by a resident of a Contracting State from the

alienation of immovable property referred to in Article 6 and

situated in the other Contracting State may be taxed in that

other State.

2. Gains derived by a resident of a Contracting State from the

alienation of shares or of a comparable interest of any kind

deriving more than 50 (fifty) per cent of their value directly or

indirectly from immovable property situated in the other

Contracting State may be taxed in that other State. However, the

provisions of this paragraph shall not apply to institutions and

entities mentioned in paragraph 3 of Article 10.

3. Gains from the alienation of movable property forming part

of the business property of a permanent establishment which an

enterprise of a Contracting State has in the other Contracting

State or of movable property pertaining to a fixed base available

to a resident of a Contracting State in the other Contracting

State for the purpose of performing independent personal

services, including such gains from the alienation of such a

permanent establishment (alone or with the whole enterprise) or

of such fixed base, may be taxed in that other State.

4. Gains derived by an enterprise of a Contracting State

operating ships or aircraft in international traffic from the

alienation of ships or aircraft operated in international traffic

or movable property pertaining to the operation of such ships or

aircraft, shall be taxable only in that State.

5. Gains from the alienation of any property other than that

referred to in paragraphs 1, 2, 3 and 4, shall be taxable

only in the Contracting State of which the alienator is a

resident.

Article 14

INDEPENDENT PERSONAL SERVICES

1. Income derived by a resident of a Contracting State in

respect of professional services or other activities of an

independent character shall be taxable only in that State except

in the following circumstances, when such income may also be

taxed in the other Contracting State:

a) if he has a fixed base regularly available to him in the

other Contracting State for the purpose of performing his

activities; in that case, only so much of the income as is

attributable to that fixed base may be taxed in that other

Contracting State; or

b) if his stay in the other Contracting State is for a period

or periods amounting to or exceeding in the aggregate 183 (one

hundred and eighty three days) days in any 12 (twelve) month

period commencing or ending in the taxable year concerned; in

that case, only so much of the income as is derived from his

activities performed in that other State may be taxed in that

other State.

2. The term "professional services" includes

especially independent scientific, literary, artistic,

educational or teaching activities as well as the independent

activities of physicians, lawyers, engineers, architects,

dentists and accountants.

Article 15

DEPENDENT PERSONAL SERVICES

1. Subject to the provisions of Articles 16, 18 and 19,

salaries, wages and other similar remuneration derived by a

resident of a Contracting State in respect of an employment shall

be taxable only in that State unless the employment is exercised

in the other Contracting State. If the employment is so

exercised, such remuneration as is derived therefrom may be taxed

in that other State.

2. Notwithstanding the provisions of paragraph 1, remuneration

derived by a resident of a Contracting State in respect of an

employment exercised in the other Contracting State shall be

taxable only in the first-mentioned State if:

a) the recipient is present in the other State for a period or

periods not exceeding in the aggregate 183 (one hundred and

eighty three days) days in any 12 (twelve) month period

commencing or ending in the taxation year concerned, and

b) the remuneration is paid by, or on behalf of, an employer

who is not a resident of the other State, and

c) the remuneration is not borne by a permanent establishment

or a fixed base which the employer has in the other State.

3. Notwithstanding the preceding provisions of this Article,

remuneration derived in respect of an employment exercised aboard

a ship or aircraft operated in international traffic by an

enterprise of a Contracting State may be taxed in that State

4. Notwithstanding the preceding provisions of this Article,

salaries, wages, allowances and other remuneration received by an

employee in a top-level managerial position in an airline or

shipping enterprise of a Contracting State, who is stationed in

the other Contracting State, shall be taxable only in the

first-mentioned State.

Article 16

DIRECTORS' FEES

Directors' fees and other similar remuneration derived by

a resident of a Contracting State in his capacity as a member of

the board of directors or any other similar organ of a company

which is a resident of the other Contracting State may be taxed

in that other State.

Article 17

ARTISTES AND SPORTPERSONS

1. Notwithstanding the provisions of Articles 14 and 15,

income derived by a resident of a Contracting State as an

entertainer, such as a theatre, motion picture, radio or

television artiste, or a musician, or as a sportsperson, from his

personal activities as such exercised in the other Contracting

State, may be taxed in that other State.

2. Where income in respect of personal activities exercised by

an entertainer or a sportsperson in his capacity as such accrues

not to the entertainer or sportsperson himself but to another

person, that income may, notwithstanding the provisions of

Articles 7, 14 and 15, be taxed in the Contracting State in which

the activities of the entertainer or sportsperson are

exercised.

3. Income derived by a resident of a Contracting State from

activities exercised in the other Contracting State as envisaged

in paragraphs 1 and 2 of this Article, shall be exempted from tax

in that other State if the visit to that other State is supported

wholly or substantially by funds of the first-mentioned State, a

political subdivision or a local authority thereof, or takes

place under a cultural agreement or arrangement between the

Governments of the Contracting States.

Article 18

PENSIONS AND ANNUITIES

1. Subject to the provisions of paragraph 2 of Article 19,

pensions and other similar remuneration and annuities paid to a

resident of a Contracting State in consideration of past

employment shall be taxable only in that State.

2. Notwithstanding the provisions of paragraph 1 of this

Article and paragraph 2 of Article 19, pensions and other similar

remuneration paid under the social security system of a

Contracting State shall be taxable only in that State.

3. The term "annuity" means a stated sum payable

periodically at stated times during life or during a specified or

ascertainable period of time under an obligation to make the

payments in return for adequate and full consideration in money

or money's worth.

Article 19

GOVERNMENT SERVICE

1. a) Salaries, wages and other similar remuneration, other

than a pension, paid by a Contracting State or a political

subdivision or a local authority thereof to an individual in

respect of services rendered to that State or subdivision or

authority shall be taxable only in that State.

b) However, such salaries, wages and other similar

remuneration shall be taxable only in the other Contracting State

if the services are rendered in that other State and the

individual is a resident of that other State who:

(i) is a national of that other State; or

(ii) did not become a resident of that other State solely for

the purpose of rendering the services.

2. a) Any pension paid by, or out of funds created by, a

Contracting State or a political subdivision or a local authority

thereof to an individual in respect of services rendered to that

State or subdivision or authority shall be taxable only in that

State.

b) However, such pension shall be taxable only in the other

Contracting State if the individual is a resident of, and a

national of, that State.

3. The provisions of Articles 15, 16, 17, and 18 shall apply

to salaries, wages and other similar remuneration, and to

pensions, in respect of services rendered in connection with a

business carried on by a Contracting State or a political

subdivision or a local authority thereof.

Article 20

TEACHERS AND RESEARCHERS

1. An individual who visits a Contracting State for the

purpose of teaching or carrying out research at the university,

college, museum or other recognised educational or scientific

institution, or under an official program of cultural exchange in

that Contracting State and who is or was immediately before that

visit a resident of the other Contracting State, shall be

exempted from taxation in the first-mentioned Contracting State

on remuneration for such teaching or research for a period not

exceeding 2 (two) years from the date of his first visit for that

purpose.

2. The provisions of paragraph 1 of this Article shall not

apply to income from research if such research is undertaken not

in the public interest but primarily for the private benefit of a

specific person or persons.

Article 21

STUDENTS AND TRAINEES

1. Payments which a student, an apprentice or a trainee

who is or was immediately before visiting a Contracting State a

resident of the other Contracting State and who is present in the

first-mentioned State solely for the purpose of his education or

training receives for the purpose of his maintenance, education

or training shall not be taxed in that State, provided that such

payments arise from sources outside that State.

2. In respect of the payments not covered by paragraph 1 of

this Article, and remuneration for dependent personal services

rendered during such education or training, a student, an

apprentice or a trainee shall be entitled to the same exemptions,

reliefs or reductions in respect of taxes on income as are

available to the residents of the Contracting State he is

visiting.

Article 22

OTHER INCOME

1. Items of income of a resident of a Contracting State,

wherever arising, not dealt with in the foregoing Articles of

this Agreement shall be taxable only in that State

2. The provisions of paragraph 1 shall not apply to income,

other than income from immovable property as defined in paragraph

2 of Article 6, if the recipient of such income, being a resident

of a Contracting State, carries on business in the other

Contracting State through a permanent establishment situated

therein, or performs in that other State independent personal

services from a fixed base situated therein, and the right or

property in respect of which the income is paid is effectively

connected with such permanent establishment or fixed base. In

such case the provisions of Article 7 or Article 14, as the case

may be, shall apply.

Article 23

ELIMINATION OF DOUBLE TAXATION

1. In the case of Latvia, double taxation shall be eliminated

as follows:

Where a resident of Latvia derives income which, in accordance

with this Agreement, may be taxed in Qatar, unless a more

favourable treatment is provided in its domestic law, Latvia

shall allow as a deduction from the tax on the income of that

resident, an amount equal to the income tax paid thereon in

Qatar.

Such deduction shall not, however, exceed that part of the

income tax in Latvia, as computed before the deduction is given,

which is attributable to the income which may be taxed in

Qatar.

2. In the case of Qatar double taxation shall be eliminated as

follows:

Where a resident of Qatar derives income which, in accordance

with the provisions of this Agreement, is taxable in Latvia, then

Qatar shall allow as a deduction from the tax on income of that

resident an amount equal to the tax paid in Latvia provided that

such deduction shall not exceed that part of the tax, as computed

before the deduction is given, which is attributable to the

income derived from Latvia.

Article 24

NON-DISCRIMINATION

1. Nationals of a Contracting State shall not be subjected in

the other Contracting State to any taxation or any requirement

connected therewith, which is other or more burdensome than the

taxation and connected requirements to which nationals of that

other State in the same circumstances, in particular with respect

to residence, are or may be subjected. This provision shall,

notwithstanding the provisions of Article 1, also apply to

persons who are not residents of one or both of the Contracting

States.

2. Stateless persons who are residents of a Contracting State

shall not be subjected in either Contracting State to any

taxation or any requirement connected therewith, which is other

or more burdensome than the taxation and connected requirements

to which nationals of the State concerned in the same

circumstances, in particular with respect to residence, are or

may be subjected.

3. The taxation on a permanent establishment which an

enterprise of a Contracting State has in the other Contracting

State shall not be less favourably levied in that other State

than the taxation levied on enterprises of that other State

carrying on the same activities. This provision shall not be

construed as obliging a Contracting State to grant to residents

of the other Contracting State any personal allowances, reliefs

and reductions for taxation purposes on account of civil status

or family responsibilities which it grants to its own

residents.

4. Except where the provisions of paragraph 1 of Article 9,

paragraph 7 of Article 11, or paragraph 6 of Article 12, apply,

interest, royalties and other disbursements paid by an enterprise

of a Contracting State to a resident of the other Contracting

State shall, for the purpose of determining the taxable profits

of such enterprise, be deductible under the same conditions as if

they had been paid to a resident of the first-mentioned

State.

5. Enterprises of a Contracting State, the capital of which is

wholly or partly owned or controlled, directly or indirectly, by

one or more residents of the other Contracting State, shall not

be subjected in the first-mentioned State to any taxation or any

requirement connected therewith which is other or more burdensome

than the taxation and connected requirements to which other

similar enterprises of the first-mentioned State are or may be

subjected.

6. The provisions of this Article shall, notwithstanding the

provisions of Article 2, apply to taxes of every kind and

description.

7. The non taxation of Qatari nationals under Qatari tax law

shall not be regarded as a discrimination under the provision of

this Article.

Article 25

MUTUAL AGREEMENT PROCEDURE

1. Where a person considers that the actions of one or both of

the Contracting States result or will result for him in taxation

not in accordance with the provisions of this Agreement, he may,

irrespective of the remedies provided by the domestic law of

those States, present his case to the competent authority of the

Contracting State of which he is a resident or, if his case comes

under paragraph 1 of Article 24, to that of the Contracting State

of which he is a national. The case must be presented within 3

(three) years from the first notification of the action resulting

in taxation not in accordance with the provisions of the

Agreement.

2. The competent authority shall endeavour, if the objection

appears to it to be justified and if it is not itself able to

arrive at a satisfactory solution, to resolve the case by mutual

agreement with the competent authority of the other Contracting

State, with a view to the avoidance of taxation which is not in

accordance with the Agreement. Any agreement reached shall be

implemented notwithstanding any time limits in the domestic law

of the Contracting States.

3. The competent authorities of the Contracting States shall

endeavour to resolve by mutual agreement any difficulties or

doubts arising as to the interpretation or application of the

Agreement. They may also consult together for the elimination of

double taxation in cases not provided for in the Agreement.

4. The competent authorities of the Contracting States may

communicate with each other directly, including through a joint

commission consisting of themselves or their representatives, for

the purpose of reaching an agreement in the sense of the

preceding paragraphs.

Article 26

EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall

exchange such information as is foreseeably relevant for carrying

out the provisions of this Agreement or to the administration or

enforcement of the domestic laws concerning taxes of every kind

and description imposed on behalf of the Contracting States, or

of their political subdivisions or local authorities, insofar as

the taxation thereunder is not contrary to the Agreement. The

exchange of information is not restricted by Articles 1 and

2.

2. Any information received under paragraph 1 by a Contracting

State shall be treated as secret in the same manner as

information obtained under the domestic laws of that State and

shall be disclosed only to persons or authorities (including

courts and administrative bodies) concerned with the assessment

or collection of, the enforcement or prosecution in respect of,

the determination of appeals in relation to the taxes referred to

in paragraph 1, or the oversight of the above. Such

persons or authorities shall use the information only for such

purposes. They may disclose the information in public court

proceedings or in judicial decisions.

3. In no case shall the provisions of paragraphs 1 and 2 be

construed so as to impose on a Contracting State the

obligation:

a) to carry out administrative measures at variance with the

laws and administrative practice of that or of the other

Contracting State;

b) to supply information which is not obtainable under the

laws or in the normal course of the administration of that or of

the other Contracting State;

c) to supply information which would disclose any trade,

business, industrial, commercial or professional secret or trade

process, or information, the disclosure of which would be

contrary to public policy (order public).

4. If information is requested by a Contracting State in

accordance with this Article, the other Contracting State shall

use its information gathering measures to obtain the requested

information, even though that other State may not need such

information for its own tax purposes. The obligation contained in

the preceding sentence is subject to the limitations of paragraph

3 but in no case shall such limitations be construed to permit a

Contracting State to decline to supply information solely because

it has no domestic interest in such information.

5. In no case shall the provisions of paragraph 3 be construed

to permit a Contracting State to decline to supply information

solely because the information is held by a bank, other financial

institution, nominee or person acting in an agency or a fiduciary

capacity or because it relates to ownership interests in a

person.

Article 27

MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

Nothing in this Agreement shall affect the fiscal privileges

of members of diplomatic missions or consular posts under the

general rules of international law or under the provisions of

special agreements.

Article 28

LIMITATION OF BENEFITS

1. Notwithstanding the provisions of any other Article of this

Agreement, a resident of a Contracting State shall not receive

the benefit of any reduction in or exemption from tax provided

for in the Agreement by the other Contracting State if the main

purpose or one of the main purposes of such resident or a person

connected with such resident was to obtain the benefits of the

Agreement.

2. The provisions of paragraph 1 shall not apply to

institutions and entities mentioned in paragraph 3 of Article

10.

Article 29

ENTRY INTO FORCE

1. The Contracting States shall notify each other in writing

through diplomatic channels of the completion of the procedures

required by their laws for bringing into force of this Agreement.

The Agreement shall enter into force on the date of the later of

these notifications.

2. The provisions of this Agreement shall have effect in both

Contracting States:

a) with regard to taxes withheld at source, in respect of

amounts paid or credited on or after the first day of January of

the calendar year immediately following the year in which the

Agreement enters into force; and

b) with regard to other taxes, in respect of taxation years

beginning on or after the first day of January of the calendar

year immediately following the year in which the Agreement enters

into force.

Article 30

TERMINATION

1. This Agreement shall remain in force until terminated by a

Contracting State. Either Contracting State may terminate the

Agreement, through diplomatic channels, by giving written notice

of termination at least 6 (six) months before the end of any

calendar year following the expiration of a period of 5 (five)

years from the date of its entry into force.

2. This Agreement shall cease to have effect in both

Contracting States:

a) with regard to taxes withheld at source, in respect of

amounts paid or credited on or after the first day of January of

the calendar year immediately following the year in which the

notice is given; and

b) with regard to other taxes, in respect of taxation years

beginning on or after the first day of January of the calendar

year immediately following the year in which the notice is

given.

In witness whereof, the undersigned, duly authorised thereto,

have signed this Agreement.

Done in duplicate at New York the twenty sixth day of

September 2014, in the Latvian, Arabic and English languages, all

texts being equally authentic. In the case of any divergence the

English text shall prevail.

For the Government of

the Republic of Latvia

Edgars Rinkēvičs

Minister of Foreign

Affairs

For the Government of

the State of Qatar

Ahmed bin Jassim Al Thani

Minister of

Economics