31. pants

1Darbības izbeigšana

2Šī konvencija ir spēkā tik ilgi, kamēr viena Līgumslēdzēja

3Valsts izbeidz tā darbību. Katra Līgumslēdzēja Valsts var izbeigt

4konvencijas darbību, pa diplomātiskajiem kanāliem iesniedzot

5rakstisku paziņojumu par izbeigšanu vismaz sešus mēnešus pirms

6jebkura kalendārā gada beigām, kas seko piektajam gadam pēc

7stāšanās spēkā. Šajā gadījumā konvencija zaudē spēku abās

8Līgumslēdzējās Valstīs:

9a) attiecībā uz nodokļiem, ko ietur ienākuma izmaksas brīdī,

10no ienākuma, kas gūts janvāra pirmajā dienā vai pēc tās,

11kalendārajā gadā, kas seko gadam, kurā ir iesniegts

12paziņojums;

13b) attiecībā uz pārējiem ienākuma un kapitāla nodokļiem -

14nodokļiem, kas maksājami par jebkuru taksācijas periodu, kas

15sākas janvāra pirmajā dienā vai pēc tās, kalendārajā gadā, kas

16seko gadam, kurā ir iesniegts paziņojums.

17To apliecinot, būdami pienācīgi pilnvaroti, šo konvenciju ir

18parakstījuši.

19Parakstīts Kopenhāgenā 2025. gada 2. oktobrī divos eksemplāros

20latviešu, vācu un angļu valodā, turklāt visi trīs teksti ir

21vienlīdz autentiski. Atšķirīgas interpretācijas gadījumā

22noteicošais ir teksts angļu valodā.

23Latvijas Republikas valdības vārdā

24Evika Siliņa

25Lihtenšteinas Firstistes valdības vārdā

26Brigite Hāsa

27Protokols

28Šodien, parakstot Latvijas Republikas valdības un

29Lihtenšteinas Firstistes valdības konvenciju par nodokļu dubultās

30uzlikšanas attiecībā uz ienākuma un kapitāla nodokļiem un par

31ļaunprātīgas izvairīšanās no nodokļu maksāšanas un nodokļu

32nemaksāšanas novēršanu apakšā parakstījušies vienojas, ka šādi

33noteikumi ir konvencijas neatņemama sastāvdaļa.

341. Attiecībā uz 2. pantu (Nodokļi, uz kuriem attiecas

35konvencija) un 22. pantu (Nodokļu dubultās uzlikšanas

36novēršana):

37Tiek saprasts, ka, ja personai, kas ir Līgumslēdzējas Valsts

38rezidents, saskaņā ar šo konvenciju ir uzliekams Lihtenšteinas

39īpašuma nodoklis kapitālam, nodokli, ko uzliek nosacītajam

40ienākumam no šāda kapitāla ("Sollertrag"),

41uzskata par iedzīvotāju ienākuma nodokli.

422. Attiecībā uz 3. panta (Vispārīgās definīcijas) 1. daļas c)

43punktu:

44Tiek saprasts, ka termins "persona" ietver

45Lihtenšteinā neaktivizētu mantojumu. Lihtenšteinā neaktivizēts

46mantojums ir mirušās personas īpašums laika posmā no nāves brīža

47līdz īpašumtiesību pārejai mantiniekam(-iem), kam saskaņā ar

48Lihtenšteinas Nodokļu likuma 7. panta 3. daļu piemēro

49nodokli.

503. Attiecībā uz 3. panta (Vispārīgās definīcijas) 1. daļas k)

51punktu:

52Tiek saprasts, ka termins "atzīts pensiju fonds"

53ietver:

54a) Latvijā, jebkuru pensiju fondu vai shēmu, uz kuru attiecas

55likums "Par valsts pensijām", Valsts fondēto pensiju

56likums un Privāto pensiju fondu likums, ieguldījumu pārvaldes

57sabiedrību, kas pārvalda valsts fondēto pensiju shēmu ieguldījumu

58plānu līdzekļus un šādu sabiedrību ieguldītos līdzekļus;

59b) Lihtenšteinā, jebkuru pensiju fondu vai shēmu, uz kuru

60attiecas Likums par vecuma un apgādnieka zaudējuma apdrošināšanu,

61Likums par invaliditātes apdrošināšanu, Likums par arodu pensiju

62fondiem un Pensiju fondu likums.

634. Attiecībā uz 4. panta (Rezidents) 1. daļu:

64Tiek saprasts, ka:

65a) Lihtenšteinas fondu ("Stiftung"),

66nodibinājumu ("Anstalt") un trasta uzņēmumu

67("Treuunternehmen mit Persönlichkeit"), kam

68nodoklis uzliekams Lihtenšteinā saskaņā ar Lihtenšteinas Nodokļu

69likuma 44. panta 1. daļu, uzskata par Lihtenšteinas

70rezidentu;

71b) Lihtenšteinas trastu, kam nodoklis uzliekams Lihtenšteinā

72saskaņā ar Lihtenšteinas Nodokļu likuma 65. pantu, neuzskata par

73Lihtenšteinas rezidentu;

74c) vienību vai organizāciju, kas nodibināta un darbojas

75vienīgi labdarības, reliģiskiem, humānās palīdzības,

76zinātniskiem, kultūras vai līdzīgiem mērķiem (vai vairākiem no

77šiem mērķiem), un kas ir nodibināta vai ir rezidents šajā valstī

78saskaņā ar tās normatīvajiem aktiem, uzskata par šīs valsts

79rezidentu neatkarīgi no tā, ka visu vai daļu tās ienākuma vai

80kapitāla pieauguma var atbrīvot no nodokļa uzlikšanas saskaņā ar

81šīs valsts normatīvajiem aktiem.

825. Attiecībā uz 4. panta (Rezidents) 1. daļu un 15. pantu

83(Direktoru atalgojums):

84Tiek saprasts, ka, izņemot 15. panta izpratnē, personas

85(tostarp privāto aktīvu struktūras saskaņā ar Lihtenšteinas

86normatīvajiem aktiem), kurām Lihtenšteinā piemērojams tikai

87minimālais uzņēmumu ienākuma nodoklis

88("Mindestertragssteuer") neuzskata par

89Lihtenšteinas rezidentiem.

906. Attiecībā uz 7. pantu (Uzņēmējdarbības peļņa):

91a) konvencijas 7. panta 1.-7. daļu izslēdz un aizstāj ar

92šādiem noteikumiem datumā, par kuru vienojas Līgumslēdzēju Valstu

93valdības, apmainoties ar diplomātiskajām notām:

94"1. Līgumslēdzējas Valsts uzņēmuma peļņai tiek uzlikti

95nodokļi tikai šajā valstī, izņemot, ja uzņēmums veic

96uzņēmējdarbību otrā Līgumslēdzējā Valstī, izmantojot tur esošu

97pastāvīgo pārstāvniecību. Ja uzņēmums veic uzņēmējdarbību

98minētajā veidā, uzņēmuma peļņai, kas attiecināma uz šo pastāvīgo

99pārstāvniecību saskaņā ar 2. daļu, var uzlikt nodokļus šajā otrā

100valstī.

1012. Šā panta un 22. panta izpratnē, par peļņu, kas katrā

102Līgumslēdzējā Valstī attiecināma uz 1. daļā minēto pastāvīgo

103pārstāvniecību, uzskata peļņu, ko tā varētu gūt, jo īpaši tās

104darījumos ar citām uzņēmuma daļām, ja tā būtu atsevišķs un

105neatkarīgs uzņēmums, kas veic tādu pašu vai līdzīgu

106uzņēmējdarbību tādos pašos vai līdzīgos apstākļos, ņemot vērā

107uzņēmuma veiktās funkcijas, izmantotos aktīvus un uzņemtos

108riskus, izmantojot pastāvīgo pārstāvniecību un citas uzņēmuma

109daļas.

1103. Ja saskaņā ar 2. daļu Līgumslēdzēja Valsts koriģē peļņu,

111kas ir attiecināma uz vienas Līgumslēdzējas Valsts uzņēmuma

112pastāvīgo pārstāvniecību, un attiecīgi uzliek nodokļus uzņēmuma

113peļņai, kam ir uzliktgi nodokļi otrā valstī, šī otra valsts, tādā

114apmērā, cik nepieciešams novērst nodokļu dubulto uzlikšanu šai

115peļņai, veic atbilstošu šai peļņai uzliktā nodokļa summas

116korekciju. Nosakot šādu korekciju, Līgumslēdzēju Valstu

117kompetentās iestādes nepieciešamības gadījumā savstarpēji

118konsultējas.

1194. Ja peļņa ietver ienākuma veidus, kur ir atrunāti atsevišķi

120citos šīs konvencijas pantos, šā panta noteikumi neietekmē šo

121citu pantu noteikumus.".

122b) ar a) punkta noteikumiem grozītie konvencijas 7. panta

1231.-4. daļas noteikumi ir spēkā attiecībā uz uzņēmuma peļņu par

124jebkuriem taksācijas periodiem, kas sākas a) punktā minētajā

125datumā vai pēc tā. Līdz brīdim, kad stājas spēkā ar a) punkta

126noteikumiem grozītie konvencijas 7. panta 1.-4. daļas noteikumi,

127turpina piemērot konvencijas 7. panta 1.-7. daļu sākotnējos

128noteikumus.

1297. Attiecībā uz 25. pantu (Informācijas apmaiņa):

130Tiek saprasts, ka šīs konvencijas mērķiem:

131a) informāciju, ar kuru apmainās, nedrīkst izpaust nevienai

132citai valstij vai suverēnai teritorijai, kas nav šīs konvencijas

133līgumslēdzēja puse;

134b) personas datus var apstrādāt un nosūtīt tādā apmērā, cik

135tas nepieciešams informācijas apmaiņai saskaņā ar 25. pantu;

136c) jebkurš informācijas pieprasījums tiek veikts

137rakstiski;

138d) tas ir spēkā attiecībā uz pieprasījumiem, kas veikti 1.

139janvārī vai pēc tā, kalendārajā gadā, kas seko gadam, kurā šī

140konvencija stājas spēkā, un tikai attiecībā uz taksācijas

141periodiem, kas sākas 1. janvārī vai pēc tā, kalendārajā gadā, kas

142seko gadam, kurā šī konvencija stājas spēkā;

143e) gadījumā, ja konvencijas darbība tiek izbeigta saskaņā ar

14431. pantu, attiecībā uz jebkādu informāciju, kas saņemta saskaņā

145ar šo konvenciju, turpina piemērot 25. panta 2. daļā minētajos

146konfidencialitātes noteikumus;

147f) šīs konvencijas spēkā stāšanās neliedz Līgumslēdzējām

148Valstīm piemērot 2004. gada 7. decembra Nolīguma starp Eiropas

149Kopienu un Lihtenšteinas Firstisti, ar ko nosaka līdzvērtīgus

150pasākumus tiem, kuri noteikti Padomes Direktīvā 2003/48/EK par

151procentu ienākumu no uzkrājumiem aplikšanu ar nodokli, kas

152grozīts ar 2015. gada 28. oktobra grozījumu protokolu,

153noteikumus, vai Konvenciju par savstarpējo administratīvo

154palīdzību nodokļu jautājumos, kas grozīta ar protokolu, ar ko

155groza Konvenciju par savstarpējo administratīvo palīdzību nodokļu

156jautājumos.

157To apliecinot, būdami pienācīgi pilnvaroti, šo konvenciju ir

158parakstījuši.

159Parakstīts Kopenhāgenā 2025. gada 2. oktobrī divos eksemplāros

160latviešu, vācu un angļu valodā, turklāt visi trīs teksti ir

161vienlīdz autentiski. Atšķirīgas interpretācijas gadījumā

162noteicošais ir teksts angļu valodā.

163Latvijas Republikas valdības vārdā

164Evika Siliņa

165Lihtenšteinas Firstistes valdības vārdā

166Brigite Hāsa

167Convention

168between the Government of the Republic of Latvia and the

169Government of the Principality of Liechtenstein for the

170elimination of double taxation with respect to taxes on income

171and on capital and the prevention of tax evasion and

172avoidance

173The Government of the Republic of Latvia and the Government of

174the Principality of Liechtenstein,

175Desiring to further develop their economic relationship and to

176enhance their co-operation in tax matters,

177Intending to conclude a Convention for the elimination of

178double taxation with respect to taxes on income and on capital

179without creating opportunities for non-taxation or reduced

180taxation through tax evasion or avoidance (including through

181treaty-shopping arrangements aimed at obtaining reliefs provided

182in this Convention for the indirect benefit of residents of third

183States),

184Have agreed as follows:

185Article 1

186Persons covered

1871. This Convention shall apply to persons who are residents of

188one or both of the Contracting States.

1892. For the purposes of this Convention, income derived by or

190through an entity or arrangement that is treated as wholly or

191partly fiscally transparent under the tax law of either

192Contracting State shall be considered to be income of a resident

193of a Contracting State but only to the extent that the income is

194treated, for purposes of taxation by that State, as the income of

195a resident of that State.

196Article 2

197Taxes covered

1981. This Convention shall apply to taxes on income and on

199capital imposed on behalf of a Contracting State or of its

200political subdivisions or local authorities, irrespective of the

201manner in which they are levied.

2022. There shall be regarded as taxes on income and on capital

203all taxes imposed on total income, on total capital, or on

204elements of income or of capital, including taxes on gains from

205the alienation of movable or immovable property, as well as taxes

206on capital appreciation.

2073. The existing taxes to which the Convention shall apply are

208in particular:

209a) in Latvia:

210(i) the enterprise income tax (uzņēmumu ienākuma

211nodoklis);

212(ii) the personal income tax (iedzīvotāju ienākuma

213nodoklis);

214(iii) the immovable property tax (nekustamā īpašuma

215nodoklis);

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

217b) in Liechtenstein:

218(i) the personal income tax (Erwerbssteuer);

219(ii) the corporate income tax (Ertragssteuer);

220(iii) the real estate capital gains tax

221(Grundstücksgewinnsteuer); and

222(iv) the wealth tax (Vermögenssteuer)

223(hereinafter referred to as "Liechtenstein

224tax").

2254. The Convention shall apply also to any identical or

226substantially similar taxes that are imposed after the date of

227signature of the Convention in addition to, or in place of, the

228existing taxes. The competent authorities of the Contracting

229States shall notify each other of any significant changes that

230have been made in their taxation laws.

231Article 3

232General definitions

2331. For the purposes of this Convention, unless the context

234otherwise requires:

235a) the terms "a Contracting State" and "the

236other Contracting State" mean the Republic of Latvia or the

237Principality of Liechtenstein as the context requires;

238b) (i) the term "Latvia" means the Republic of

239Latvia and, when used in the geographical sense, means the

240territory of the Republic of Latvia and any other area adjacent

241to the territorial waters of the Republic of Latvia within which

242under the laws of Latvia and in accordance with international

243law, the rights of Latvia may be exercised with respect to the

244sea bed and its sub-soil and their natural resources;

245(ii) the term "Liechtenstein" means the Principality

246of Liechtenstein, and, when used in a geographical sense, the

247area of the sovereign territory of the Principality of

248Liechtenstein in accordance with international law and its

249domestic laws;

250c) the term "person" includes an individual, a

251company, a dormant inheritance and any other body of persons;

252d) the term "company" means any body corporate or

253any entity that is treated as a body corporate for tax

254purposes;

255e) the term "enterprise" applies to the carrying on

256of any business;

257f) the terms "enterprise of a Contracting State" and

258"enterprise of the other Contracting State" mean

259respectively an enterprise carried on by a resident of a

260Contracting State and an enterprise carried on by a resident of

261the other Contracting State;

262g) the term "international traffic" means any

263transport by a ship or aircraft operated by an enterprise of a

264Contracting State, except when the ship or aircraft is operated

265solely between places in the other Contracting State;

266h) the term "competent authority" means:

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

268representative;

269(ii) in Liechtenstein, the Fiscal Authority;

270i) the term "national", in relation to a Contracting

271State, means:

272(i) any individual possessing the nationality or citizenship

273of that Contracting State; and

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

275status as such from the laws in force in that Contracting

276State;

277j) the term "business" includes the performance of

278professional services and of other activities of an independent

279character;

280k) the term "recognised pension fund" of a State

281means an entity or arrangement established in that State that is

282treated as a separate person under the taxation laws of that

283State and:

284(i) that is established and operated exclusively or almost

285exclusively to administer or provide retirement benefits and

286ancillary or incidental benefits to individuals and that is

287regulated as such by that State or one of its political

288subdivisions or local authorities; or

289(ii) that is established and operated exclusively or almost

290exclusively to invest funds for the benefit of entities or

291arrangements referred to in subdivision (i).

2922. As regards the application of the Convention at any time by

293a Contracting State, any term not defined therein shall, unless

294the context otherwise requires, have the meaning that it has at

295that time under the law of that State for the purposes of the

296taxes to which the Convention applies, any meaning under the

297applicable tax laws of that State prevailing over a meaning given

298to the term under other laws of that State.

299Article 4

300Resident

3011. For the purposes of this Convention, the term

302"resident of a Contracting State" means any person who,

303under the laws of that State, is liable to tax therein by reason

304of his domicile, residence, place of management, place of

305incorporation or any other criterion of a similar nature and also

306includes that State and any political subdivision or local

307authority thereof as well as a recognised pension fund of that

308State. This term, however, does not include any person who is

309liable to tax in that State in respect only of income from

310sources in that State or capital situated therein.

3112. Where by reason of the provisions of paragraph 1 an

312individual is a resident of both Contracting States, then his

313status shall be determined as follows:

314a) he shall be deemed to be a resident only of the State in

315which he has a permanent home available to him; if he has a

316permanent home available to him in both States, he shall be

317deemed to be a resident only of the State with which his personal

318and economic relations are closer (centre of vital

319interests);

320b) if the State in which he has his centre of vital interests

321cannot be determined, or if he has not a permanent home available

322to him in either State, he shall be deemed to be a resident only

323of the State in which he has an habitual abode;

324c) if he has an habitual abode in both States or in neither of

325them, he shall be deemed to be a resident only of the State of

326which he is a national;

327d) if he is a national of both States or of neither of them,

328the competent authorities of the Contracting States shall settle

329the question by mutual agreement.

3303. Where by reason of the provisions of paragraph 1 a person

331other than an individual is a resident of both Contracting

332States, the competent authorities of the Contracting States shall

333endeavour to determine by mutual agreement the Contracting State

334of which such person shall be deemed to be a resident of the

335purposes of the Convention, having regard to its place of

336effective management, the place where it is incorporated or

337otherwise constituted and any other relevant factors. In the

338absence of such agreement, such person shall not be entitled to

339any relief or exemption from tax provided by this Convention

340except to the extent and in such manner as may be agreed upon by

341the competent authorities of the Contracting States.

342Article 5

343Permanent establishment

3441. For the purposes of this Convention, the term

345"permanent establishment" means a fixed place of

346business through which the business of an enterprise is wholly or

347partly carried on.

3482. The term "permanent establishment" includes

349especially:

350a) a place of management;

351b) a branch;

352c) an office;

353d) a factory;

354e) a workshop; and

355f) a mine, an oil or gas well, a quarry or any other place of

356extraction of natural resources.

3573. The term "permanent establishment" also

358includes:

359a) a building site, construction, assembly or installation

360project, but only if it lasts more than nine months;

361b) activities carried on offshore in a Contracting State in

362connection with the exploration or exploitation of the sea bed

363and sub-soil and their natural resources situated in that State,

364if such activities are carried on for a period or periods

365exceeding in the aggregate 30 days in any twelve month period

366commencing or ending in the taxable period concerned.

3674. Notwithstanding the preceding provisions of this Article,

368the term "permanent establishment" shall be deemed not

369to include:

370a) the use of facilities solely for the purpose of storage,

371display or delivery of goods or merchandise belonging to the

372enterprise;

373b) the maintenance of a stock of goods or merchandise

374belonging to the enterprise solely for the purpose of storage,

375display or delivery;

376c) the maintenance of a stock of goods or merchandise

377belonging to the enterprise solely for the purpose of processing

378by another enterprise;

379d) the maintenance of a fixed place of business solely for the

380purpose of purchasing goods or merchandise or of collecting

381information, for the enterprise;

382e) the maintenance of a fixed place of business solely for the

383purpose of carrying on, for the enterprise, any other activity of

384a preparatory or auxiliary character;

385f) the maintenance of a fixed place of business solely for any

386combination of activities mentioned in sub-paragraphs a) to e),

387provided that the overall activity of the fixed place of business

388resulting from this combination is of a preparatory or auxiliary

389character.

3905. Notwithstanding the provisions of paragraphs 1 and 2 but

391subject to the provisions of paragraph 6, where a person is

392acting in a Contracting State on behalf of an enterprise and in

393doing so, habitually concludes contracts, or habitually plays the

394principal role leading to the conclusion of contracts that are

395routinely concluded without material modification by the

396enterprise, and these contracts are:

397a) in the name of the enterprise, or

398b) for the transfer of the ownership of, or for the granting

399of the right to use, property owned by that enterprise or that

400the enterprise has the right to use, or

401c) for the provision of services by that enterprise,

402that enterprise shall be deemed to have a permanent

403establishment in that State in respect of any activities which

404that person undertakes for the enterprise, unless the activities

405of such person are limited to those mentioned in paragraph 4

406which, if exercised through a fixed place of business, would not

407make this fixed place of business a permanent establishment under

408the provisions of that paragraph.

4096. An enterprise shall not be deemed to have a permanent

410establishment in a Contracting State merely because it carries on

411business in that State through a broker, general commission agent

412or any other agent of an independent status, provided that such

413persons are acting in the ordinary course of their business.

4147. The fact that a company which is a resident of a

415Contracting State controls or is controlled by a company which is

416a resident of the other Contracting State, or which carries on

417business in that other State (whether through a permanent

418establishment or otherwise), shall not of itself constitute

419either company a permanent establishment of the other.

420Article 6

421Income from immovable property

4221. Income derived by a resident of a Contracting State from

423immovable property (including income from agriculture or

424forestry) situated in the other Contracting State may be taxed in

425that other State.

4262. The term "immovable property" shall have the

427meaning which it has under the law of the Contracting State in

428which the property in question is situated. The term shall in any

429case include property accessory to immovable property, livestock

430and equipment used in agriculture and forestry, rights to which

431the provisions of general law respecting landed property apply,

432any option or similar right to acquire immovable property,

433usufruct of immovable property and rights to variable or fixed

434payments as consideration for the working of, or the right to

435work, mineral deposits, sources and other natural resources;

436ships and aircraft shall not be regarded as immovable

437property.

4383. The provisions of paragraph 1 shall apply to income derived

439from the direct use, letting, or use in any other form of

440immovable property, as well as income from the alienation of

441immovable property.

4424. The provisions of paragraphs 1 and 3 shall also apply to

443the income from immovable property of an enterprise.

444Article 7

445Business profits

4461. Profits of an enterprise of a Contracting State shall be

447taxable only in that State unless the enterprise carries on

448business in the other Contracting State through a permanent

449establishment situated therein. If the enterprise carries on

450business as aforesaid, the profits of the enterprise may be taxed

451in the other State but only so much of them as is attributable to

452that permanent establishment.

4532. Subject to the provisions of paragraph 3, where an

454enterprise of a Contracting State carries on business in the

455other Contracting State through a permanent establishment

456situated therein, there shall in each Contracting State be

457attributed to that permanent establishment the profits which it

458might be expected to make if it were a distinct and separate

459enterprise engaged in the same or similar activities under the

460same or similar conditions and dealing wholly independently with

461the enterprise of which it is a permanent establishment.

4623. In determining the profits of a permanent establishment in

463a Contracting State, there shall be allowed as deductions

464expenses (other than expenses which would not be deductible if

465that permanent establishment were a separate enterprise of that

466Contracting State) which are incurred for the purposes of the

467permanent establishment, including executive and general

468administrative expenses so incurred, whether in the State in

469which the permanent establishment is situated or elsewhere.

4704. Insofar as it has been customary in a Contracting State to

471determine the profits to be attributed to a permanent

472establishment on the basis of an apportionment of the total

473profits of the enterprise to its various parts, nothing in

474paragraph 2 shall preclude that Contracting State from

475determining the profits to be taxed by such an apportionment as

476may be customary; the method of apportionment adopted shall,

477however, be such that the result shall be in accordance with the

478principles contained in this Article.

4795. No profits shall be attributed to a permanent establishment

480by reason of the mere purchase by that permanent establishment of

481goods or merchandise for the enterprise.

4826. For the purposes of the preceding paragraphs, the profits

483to be attributed to the permanent establishment shall be

484determined by the same method year by year unless there is good

485and sufficient reason to the contrary.

4867. Where profits include items of income which are dealt with

487separately in other Articles of this Convention, then the

488provisions of those Articles shall not be affected by the

489provisions of this Article.

490Article 8

491International shipping and air transport

4921. Profits of an enterprise of a Contracting State from the

493operation of ships or aircraft in international traffic shall be

494taxable only in that State.

4952. The provisions of paragraph 1 shall also apply to profits

496from the participation in a pool, a joint business or an

497international operating agency.

498Article 9

499Associated enterprises

5001. Where

501a) an enterprise of a Contracting State participates directly

502or indirectly in the management, control or capital of an

503enterprise of the other Contracting State, or

504b) the same persons participate directly or indirectly in the

505management, control or capital of an enterprise of a Contracting

506State and an enterprise of the other Contracting State,

507and in either case conditions are made or imposed between the

508two enterprises in their commercial or financial relations which

509differ from those which would be made between independent

510enterprises, then any profits which would, but for those

511conditions, have accrued to one of the enterprises, but, by

512reason of those conditions, have not so accrued, may be included

513in the profits of that enterprise and taxed accordingly.

5142. Where a Contracting State includes in the profits of an

515enterprise of that State - and taxes accordingly - profits on

516which an enterprise of the other Contracting State has been

517charged to tax in that other State and the profits so included

518are profits which would have accrued to the enterprise of the

519first-mentioned State if the conditions made between the two

520enterprises had been those which would have been made between

521independent enterprises, then that other State shall make an

522appropriate adjustment to the amount of the tax charged therein

523on those profits. In determining such adjustment, due regard

524shall be had to the other provisions of this Convention and the

525competent authorities of the Contracting States shall if

526necessary consult each other.

527Article 10

528Dividends

5291. Dividends paid by a company which is a resident of a

530Contracting State to a resident of the other Contracting State

531may be taxed in that other State.

5322. However, such dividends may also be taxed in the

533Contracting State of which the company paying the dividends is a

534resident and according to the laws of that State, but if the

535beneficial owner of the dividends is a resident of the other

536Contracting State, the tax so charged shall not exceed:

537a) 0 per cent of the gross amount of the dividends if the

538beneficial owner is a company (other than a partnership);

539b) 10 per cent of the gross amount of the dividends in all

540other cases.

541This paragraph shall not affect the taxation of the company in

542respect of the profits out of which the dividends are paid.

5433. The term "dividends" as used in this Article

544means income from shares, "jouissance" shares or

545"jouissance" rights, mining shares, founders' shares or

546other rights, not being debt-claims, participating in profits, as

547well as income from other rights which is subjected to the same

548taxation treatment as income from shares by the laws of the State

549of which the company making the distribution is a resident.

5504. The provisions of paragraph 1 and 2 shall not apply if the

551beneficial owner of the dividends, being a resident of a

552Contracting State, carries on business in the other Contracting

553State of which the company paying the dividends is a resident

554through a permanent establishment situated therein and the

555holding in respect of which the dividends are paid is effectively

556connected with such permanent establishment. In such case the

557provisions of Article 7 shall apply.

5585. Where a company which is a resident of a Contracting State

559derives profits or income from the other Contracting State, that

560other State may not impose any tax on the dividends paid by the

561company, except insofar as such dividends are paid to a resident

562of that other State or insofar as the holding in respect of which

563the dividends are paid is effectively connected with a permanent

564establishment situated in that other State, nor subject the

565company's undistributed profits to a tax on the company's

566undistributed profits, even if the dividends paid or the

567undistributed profits consist wholly or partly of profits or

568income arising in such other State.

569Article 11

570Interest

5711. Interest arising in a Contracting State and paid to a

572resident of the other Contracting State may be taxed in that

573other State.

5742. However, such interest may also be taxed in the Contracting

575State in which it arises and according to the laws of that State,

576but if the beneficial owner of the interest is a resident of the

577other Contracting State, the tax so charged shall not exceed:

578a) 0 per cent of the gross amount of the interest if the

579interest is paid by a company that is a resident of a Contracting

580State to a company (other than a partnership) that is a resident

581of the other Contracting State and is the beneficial owner of the

582interest;

583b) 10 per cent of the gross amount of the interest in all

584other cases.

5853. Notwithstanding the provisions of sub-paragraph b) of

586paragraph 2, interest arising in a Contracting State and paid to

587the other Contracting State or to a political subdivision or

588local authority thereof, to the Central Bank of that other State,

589or to a recognised pension fund of the other State shall be

590taxable only in that other State.

5914. The term "interest" as used in this Article means

592income from debt-claims of every kind, whether or not secured by

593mortgage and whether or not carrying a right to participate in

594the debtor's profits, and in particular, income from government

595securities and income from bonds or debentures, including

596premiums and prizes attaching to such securities, bonds or

597debentures. The term "interest" shall not include any

598income which is treated as a dividend under the provisions of

599Article 10. Penalty charges for late payment shall not be

600regarded as interest for the purpose of this Article.

6015. The provisions of paragraph 1, 2 and 3 shall not apply if

602the beneficial owner of the interest, being a resident of a

603Contracting State, carries on business in the other Contracting

604State in which the interest arises through a permanent

605establishment situated therein and the debt-claim in respect of

606which the interest is paid is effectively connected with such

607permanent establishment. In such case the provisions of Article 7

608shall apply.

6096. Interest shall be deemed to arise in a Contracting State

610when the payer is a resident of that State. Where, however, the

611person paying the interest, whether he is a resident of a

612Contracting State or not, has in a Contracting State a permanent

613establishment in connection with which the indebtedness on which

614the interest is paid was incurred, and such interest is borne by

615such permanent establishment, then such interest shall be deemed

616to arise in the State in which the permanent establishment is

617situated.

6187. Where, by reason of a special relationship between the

619payer and the beneficial owner or between both of them and some

620other person, the amount of the interest, having regard to the

621debt-claim for which it is paid, exceeds the amount which would

622have been agreed upon by the payer and the beneficial owner in

623the absence of such relationship, the provisions of this Article

624shall apply only to the last-mentioned amount. In such case, the

625excess part of the payments shall remain taxable according to the

626laws of each Contracting State, due regard being had to the other

627provisions of this Convention.

628Article 12

629Royalties

6301. Royalties arising in a Contracting State and beneficially

631owned by a resident of the other Contracting State may be taxed

632in that other State.

6332. However, such royalties may also be taxed in the

634Contracting State in which they arise and according to the laws

635of that State, but if the beneficial owner of the royalties is a

636resident of the other Contracting State, the tax so charged shall

637not exceed:

638a) 0 per cent of the gross amount of the royalties if the

639royalties are paid by a company that is a resident of a

640Contracting State to a company (other than a partnership) that is

641a resident of the other Contracting State and is the beneficial

642owner of the royalties;

643b) 5 per cent of the gross amount of the royalties in all

644other cases.

6453. The term "royalties" as used in this Article

646means payments of any kind received as a consideration for the

647use of, or the right to use, any copyright of literary, artistic

648or scientific work including cinematograph films and films or

649tapes for radio or television broadcasting, any patent, trade

650mark, design or model, plan, secret formula or process, or for

651the use of, or the right to use, industrial, commercial or

652scientific equipment, or for information concerning industrial,

653commercial or scientific experience.

6544. The provisions of paragraphs 1 and 2 shall not apply if the

655beneficial owner of the royalties, being a resident of a

656Contracting State, carries on business in the other Contracting

657State in which the royalties arise through a permanent

658establishment situated therein and the right or property in

659respect of which the royalties are paid is effectively connected

660with such permanent establishment. In such case the provisions of

661Article 7 shall apply.

6625. Royalties shall be deemed to arise in a Contracting State

663when the payer is a resident of that State. Where, however, the

664person paying the royalties, whether he is a resident of a

665Contracting State or not, has in a Contracting State a permanent

666establishment in connection with which the liability to pay the

667royalties was incurred, and such royalties are borne by such

668permanent establishment, then such royalties shall be deemed to

669arise in the State in which the permanent establishment is

670situated.

6716. Where, by reason of a special relationship between the

672payer and the beneficial owner or between both of them and some

673other person, the amount of the royalties, having regard to the

674use, right or information for which they are paid, exceeds the

675amount which would have been agreed upon by the payer and the

676beneficial owner in the absence of such relationship, the

677provisions of this Article shall apply only to the last-mentioned

678amount. In such case, the excess part of the payments shall

679remain taxable according to the laws of each Contracting State,

680due regard being had to the other provisions of this

681Convention.

682Article 13

683Capital gains

6841. Gains derived by a resident of a Contracting State from the

685alienation of immovable property referred to in Article 6 and

686situated in the other Contracting State may be taxed in that

687other State.

6882. Gains from the alienation of movable property forming part

689of the business property of a permanent establishment which an

690enterprise of a Contracting State has in the other Contracting

691State, including such gains from the alienation of such a

692permanent establishment (alone or with the whole enterprise), may

693be taxed in that other State.

6943. Gains that an enterprise of a Contracting State that

695operates ships or aircraft in international traffic derives from

696the alienation of such ships or aircraft, or of movable property

697pertaining to the operation of such ships or aircraft, shall be

698taxable only in that State.

6994. Gains derived by a resident of a Contracting State from the

700alienation of shares or comparable interests, such as interests

701in a partnership or trust, may be taxed in the other Contracting

702State if, at any time during the 365 days preceding the

703alienation, these shares or comparable interests derived more

704than 50 per cent of their value directly or indirectly from

705immovable property, as defined in Article 6, situated in that

706other State.

7075. Gains from the alienation of any property, other than that

708referred to in paragraphs 1, 2, 3 and 4, shall be taxable only in

709the Contracting State of which the alienator is a resident.

710Article 14

711Income from employment

7121. Subject to the provisions of Articles 15, 17 and 18,

713salaries, wages and other similar remuneration derived by a

714resident of a Contracting State in respect of an employment shall

715be taxable only in that State unless the employment is exercised

716in the other Contracting State. If the employment is so

717exercised, such remuneration as is derived therefrom may be taxed

718in that other State.

7192. Notwithstanding the provisions of paragraph 1, remuneration

720derived by a resident of a Contracting State in respect of an

721employment exercised in the other Contracting State shall be

722taxable only in the first-mentioned State if:

723a) the recipient is present in the other State for a period or

724periods not exceeding in the aggregate 183 days in any twelve

725month period commencing or ending in the fiscal year concerned;

726and

727b) the remuneration is paid by, or on behalf of, an employer

728who is not a resident of the other State; and

729c) the remuneration is not borne by a permanent establishment

730which the employer has in the other State.

7313. Notwithstanding the preceding provisions of this Article,

732remuneration derived by a resident of a Contracting State in

733respect of an employment exercised aboard a ship or aircraft

734operated in international traffic by an enterprise of the other

735Contracting State may be taxed in that State.

736Article 15

737Directors' fees

738Directors' fees and other similar remuneration derived by a

739resident of a Contracting State in his capacity as a member of

740the board of directors or any other similar organ of a company

741which is a resident of the other Contracting State may be taxed

742in that other State.

743Article 16

744Entertainers and sportspersons

7451. Notwithstanding the provisions of Articles 7 and 14, income

746derived by a resident of a Contracting State as an entertainer,

747such as a theatre, motion picture, radio or television artiste,

748or a musician, or as a sportsperson, from that resident's

749personal activities as such exercised in the other Contracting

750State, may be taxed in that other State.

7512. Where income in respect of personal activities exercised by

752an entertainer or a sportsperson acting as such accrues not to

753the entertainer or sportsperson but to another person, that

754income may, notwithstanding the provisions of Articles 7 and 14,

755be taxed in the Contracting State in which the activities of the

756entertainer or sportsperson are exercised.

7573. The provisions of paragraphs 1 and 2 shall not apply to

758income derived from activities exercised in a Contracting State

759by an entertainer or a sportsperson if the visit to that State is

760wholly or mainly supported by public funds of one or both of the

761Contracting States or political subdivisions or local authorities

762or statutory bodies thereof. In such case, the income shall be

763taxable only in the Contracting State in which the entertainer or

764the sportsperson is a resident.

765Article 17

766Pensions

7671. Subject to the provisions of paragraph 2 of Article 18,

768pensions and other similar remuneration (including lump-sum

769payments) paid to a resident of a Contracting State in

770consideration of past employment shall be taxable only in that

771State.

7722. Notwithstanding the provisions of paragraph 1 of this

773Article and paragraph 2 of Article 18, pensions and other similar

774remuneration (including lump-sum payments) paid under the social

775security system of a Contracting State may be taxed in that

776State.

777Article 18

778Government service

7791. a) Salaries, wages and other similar remuneration, other

780than a pension, paid by a Contracting State or a political

781subdivision or a local authority thereof to an individual in

782respect of services rendered to that State or subdivision or

783authority shall be taxable only in that State.

784b) However, such salaries, wages and other similar

785remuneration shall be taxable only in the other Contracting State

786if the services are rendered in that State and the individual is

787a resident of that State who:

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

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

790purpose of rendering the services.

7912. a) Any pension and other similar remuneration (including

792lump-sum payments) paid by, or out of funds created by, a

793Contracting State or a political subdivision or a local authority

794thereof to an individual in respect of services rendered to that

795State or subdivision or authority shall be taxable only in that

796State.

797b) However, such pensions and other similar remuneration

798(including lump-sum payments) shall be taxable only in the other

799Contracting State if the individual is a resident of, and a

800national of, that State.

8013. The provisions of Articles 14, 15, 16, and 17 shall apply

802to salaries, wages, pensions, and other similar remuneration

803(including lump-sum payments) in respect of services rendered in

804connection with a business carried on by a Contracting State or a

805political subdivision or a local authority thereof.

806Article 19

807Students

808Payments which a student, an apprentice or a trainee who is or

809was immediately before visiting a Contracting State a resident of

810the other Contracting State and who is present in the

811first-mentioned State solely for the purpose of his education or

812training receives for the purpose of his maintenance, education

813or training shall not be taxed in that State, provided that such

814payments arise from sources outside that State.

815Article 20

816Other income

8171. Items of income of a resident of a Contracting State,

818wherever arising, not dealt with in the foregoing Articles of

819this Convention shall be taxable only in that State.

8202. The provisions of paragraph 1 shall not apply to income,

821other than income from immovable property as defined in paragraph

8222 of Article 6, if the recipient of such income, being a resident

823of a Contracting State, carries on business in the other

824Contracting State through a permanent establishment situated

825therein and the right or property in respect of which the income

826is paid is effectively connected with such permanent

827establishment. In such case the provisions of Article 7 shall

828apply.

829Article 21

830Capital

8311. Capital represented by immovable property referred to in

832Article 6, owned by a resident of a Contracting State and

833situated in the other Contracting State, may be taxed in that

834other State.

8352. Capital represented by movable property forming part of the

836business property of a permanent establishment which an

837enterprise of a Contracting State has in the other Contracting

838State may be taxed in that other State.

8393. Capital represented by ships and aircraft operated in

840international traffic by an enterprise of a Contracting State and

841by movable property pertaining to the operation of such ships or

842aircraft, shall be taxable only in that State.

8434. All other elements of capital of a resident of a

844Contracting State shall be taxable only in that State.

845Article 22

846Elimination of double taxation

8471. In Latvia, double taxation shall be eliminated as

848follows:

849Where a resident of Latvia derives income or owns capital

850which, in accordance with this Convention, may be taxed in

851Liechtenstein, unless a more favourable treatment is provided in

852its domestic law, Latvia shall allow:

853a) as a deduction from the tax on the income of that resident,

854an amount equal to the income tax paid thereon in

855Liechtenstein;

856b) as a deduction from the tax on the capital of that

857resident, an amount equal to the capital tax paid thereon in

858Liechtenstein.

859Such deduction in either case shall not, however, exceed that

860part of the income tax or capital tax in Latvia, as computed

861before the deduction is given, which is attributable, as the case

862may be, to the income or the capital which may be taxed in

863Liechtenstein.

8642. Subject to the provisions of the laws of Liechtenstein

865regarding the elimination of double taxation, which shall not

866affect the general principle hereof, double taxation shall be

867eliminated as follows:

868a) Where a resident of Liechtenstein derives income or owns

869capital which, in accordance with the provisions of this

870Convention, may be taxed in Latvia, Liechtenstein shall, subject

871to the provisions of sub-paragraph b), exempt such income or

872capital from tax, but may nevertheless, in calculating the amount

873of tax on the remaining income or capital of such resident, take

874into account the exempted income or capital.

875b) Where a resident of Liechtenstein derives items of income

876which, in accordance with the provisions of Articles 10, 11, 12,

87714, 15, 16, and 17, may be taxed in Latvia, Liechtenstein shall

878credit against the Liechtenstein tax on this income the tax paid

879in accordance with the law of Latvia and with the provisions of

880this Convention. The amount of tax to be credited shall not,

881however, exceed the Liechtenstein tax due on the income derived

882from Latvia.

883c) Where a resident of Liechtenstein derives items of income

884or owns capital which, in accordance with the provisions of this

885Convention, shall be taxable only in Latvia, Liechtenstein shall

886exempt that income or capital from tax, but may nevertheless, in

887calculating the amount of tax on the remaining income or capital

888of such resident, take into account the exempted income or

889capital.

890Article 23

891Non-discrimination

8921. Nationals of a Contracting State shall not be subjected in

893the other Contracting State to any taxation or any requirement

894connected therewith, which is other or more burdensome than the

895taxation and connected requirements to which nationals of that

896other State in the same circumstances, in particular with respect

897to residence, are or may be subjected. This provision shall,

898notwithstanding the provisions of Article 1, also apply to

899persons who are not residents of one or both of the Contracting

900States.

9012. Stateless persons who are residents of a Contracting State

902shall not be subjected in either Contracting State to any

903taxation or any requirement connected therewith, which is other

904or more burdensome than the taxation and connected requirements

905to which nationals of the State concerned in the same

906circumstances, in particular with respect to residence, are or

907may be subjected.

9083. The taxation on a permanent establishment which an

909enterprise of a Contracting State has in the other Contracting

910State shall not be less favourably levied in that other State

911than the taxation levied on enterprises of that other State

912carrying on the same activities. This provision shall not be

913construed as obliging a Contracting State to grant to residents

914of the other Contracting State any personal allowances, reliefs

915and reductions for taxation purposes on account of civil status

916or family responsibilities which it grants to its own

917residents.

9184. Except where the provisions of paragraph 1 of Article 9,

919paragraph 7 of Article 11, or paragraph 6 of Article 12, apply,

920interest, royalties and other disbursements paid by an enterprise

921of a Contracting State to a resident of the other Contracting

922State shall, for the purpose of determining the taxable profits

923of such enterprise, be deductible under the same conditions as if

924they had been paid to a resident of the first-mentioned State.

925Similarly, any debts of an enterprise of a Contracting State to a

926resident of the other Contracting State shall, for the purpose of

927determining the taxable capital of such enterprise, be deductible

928under the same conditions as if they had been contracted to a

929resident of the first-mentioned State.

9305. Enterprises of a Contracting State, the capital of which is

931wholly or partly owned or controlled, directly or indirectly, by

932one or more residents of the other Contracting State, shall not

933be subjected in the first-mentioned State to any taxation or any

934requirement connected therewith which is other or more burdensome

935than the taxation and connected requirements to which other

936similar enterprises of the first-mentioned State are or may be

937subjected.

9386. The provisions of this Article shall, notwithstanding the

939provisions of Article 2, apply to taxes of every kind and

940description.

941Article 24

942Mutual agreement procedure

9431. Where a person considers that the actions of one or both of

944the Contracting States result or will result for him in taxation

945not in accordance with the provisions of this Convention, he may,

946irrespective of the remedies provided by the domestic law of

947those States, present his case to the competent authority of

948either Contracting State. The case must be presented within three

949years from the first notification of the action resulting in

950taxation not in accordance with the provisions of the

951Convention.

9522. The competent authority shall endeavour, if the objection

953appears to it to be justified and if it is not itself able to

954arrive at a satisfactory solution, to resolve the case by mutual

955agreement with the competent authority of the other Contracting

956State, with a view to the avoidance of taxation which is not in

957accordance with the Convention. Any agreement reached shall be

958implemented notwithstanding any time limits in the domestic law

959of the Contracting States.

9603. The competent authorities of the Contracting States shall

961endeavour to resolve by mutual agreement any difficulties or

962doubts arising as to the interpretation or application of the

963Convention. They may also consult together for the elimination of

964double taxation in cases not provided for in the Convention.

9654. The competent authorities of the Contracting States may

966communicate with each other directly, including through a joint

967commission consisting of themselves or their representatives, for

968the purpose of reaching an agreement in the sense of the

969preceding paragraphs.

970Article 25

971Exchange of information

9721. The competent authorities of the Contracting States shall

973exchange such information as is foreseeably relevant for carrying

974out the provisions of this Convention or to the administration or

975enforcement of the domestic laws concerning taxes of every kind

976and description imposed on behalf of the Contracting States, or

977of their political subdivisions or local authorities, insofar as

978the taxation thereunder is not contrary to the Convention. The

979exchange of information is not restricted by Articles 1 and

9802.

9812. Any information received under paragraph 1 by a Contracting

982State shall be treated as secret in the same manner as

983information obtained under the domestic laws of that State and

984shall be disclosed only to persons or authorities (including

985courts and administrative bodies) concerned with the assessment

986or collection of, the enforcement or prosecution in respect of,

987the determination of appeals in relation to the taxes referred to

988in paragraph 1, or the oversight of the above. Such persons or

989authorities shall use the information only for such purposes.

990They may disclose the information in public court proceedings or

991in judicial decisions. Notwithstanding the foregoing, information

992received by a Contracting State may be used for other purposes

993when such information may be used for such other purposes under

994the laws of both States and the competent authority of the

995supplying State authorises such use.

9963. In no case shall the provisions of paragraphs 1 and 2 be

997construed so as to impose on a Contracting State the

998obligation:

999a) to carry out administrative measures at variance with the

1000laws and administrative practice of that or of the other

1001Contracting State;

1002b) to supply information which is not obtainable under the

1003laws or in the normal course of the administration of that or of

1004the other Contracting State;

1005c) to supply information which would disclose any trade,

1006business, industrial, commercial or professional secret or trade

1007process, or information the disclosure of which would be contrary

1008to public policy (ordre public).

10094. If information is requested by a Contracting State in

1010accordance with this Article, the other Contracting State shall

1011use its information gathering measures to obtain the requested

1012information, even though that other State may not need such

1013information for its own tax purposes. The obligation contained in

1014the preceding sentence is subject to the limitations of paragraph

10153 but in no case shall such limitations be construed to permit a

1016Contracting State to decline to supply information solely because

1017it has no domestic interest in such information.

10185. In no case shall the provisions of paragraph 3 be construed

1019to permit a Contracting State to decline to supply information

1020solely because the information is held by a bank, other financial

1021institution, nominee or person acting in an agency or a fiduciary

1022capacity or because it relates to ownership interests in a

1023person.

1024Article 26

1025Assistance in the collection of taxes

10261. The Contracting States shall lend assistance to each other

1027in the collection of revenue claims. This assistance is not

1028restricted by Articles 1 and 2. The competent authorities of the

1029Contracting States may by mutual agreement settle the mode of

1030application of this Article.

10312. The term "revenue claim" as used in this Article

1032means an amount owed in respect of taxes of every kind and

1033description imposed on behalf of the Contracting States, or of

1034their political subdivisions or local authorities, insofar as the

1035taxation thereunder is not contrary to this Convention or any

1036other instrument to which the Contracting States are parties, as

1037well as interest, administrative penalties and costs of

1038collection or conservancy related to such amount.

10393. When a revenue claim of a Contracting State is enforceable

1040under the laws of that State and is owed by a person who, at that

1041time, cannot, under the laws of that State, prevent its

1042collection, that revenue claim shall, at the request of the

1043competent authority of that State, be accepted for purposes of

1044collection by the competent authority of the other Contracting

1045State. That revenue claim shall be collected by that other State

1046in accordance with the provisions of its laws applicable to the

1047enforcement and collection of its own taxes as if the revenue

1048claim were a revenue claim of that other State.

10494. When a revenue claim of a Contracting State is a claim in

1050respect of which that State may, under its law, take measures of

1051conservancy with a view to ensure its collection, that revenue

1052claim shall, at the request of the competent authority of that

1053State, be accepted for purposes of taking measures of conservancy

1054by the competent authority of the other Contracting State. That

1055other State shall take measures of conservancy in respect of that

1056revenue claim in accordance with the provisions of its laws as if

1057the revenue claim were a revenue claim of that other State even

1058if, at the time when such measures are applied, the revenue claim

1059is not enforceable in the first-mentioned State or is owed by a

1060person who has a right to prevent its collection.

10615. Notwithstanding the provisions of paragraphs 3 and 4, a

1062revenue claim accepted by a Contracting State for purposes of

1063paragraph 3 or 4 shall not, in that State, be subject to the time

1064limits or accorded any priority applicable to a revenue claim

1065under the laws of that State by reason of its nature as such. In

1066addition, a revenue claim accepted by a Contracting State for the

1067purposes of paragraph 3 or 4 shall not, in that State, have any

1068priority applicable to that revenue claim under the laws of the

1069other Contracting State.

10706. Proceedings with respect to the existence, validity or the

1071amount of a revenue claim of a Contracting State shall not be

1072brought before the courts or administrative bodies of the other

1073Contracting State.

10747. Where, at any time after a request has been made by a

1075Contracting State under paragraph 3 or 4 and before the other

1076Contracting State has collected and remitted the relevant revenue

1077claim to the first-mentioned State, the relevant revenue claim

1078ceases to be

1079a) in the case of a request under paragraph 3, a revenue claim

1080of the first-mentioned State that is enforceable under the laws

1081of that State and is owed by a person who, at that time, cannot,

1082under the laws of that State, prevent its collection, or

1083b) in the case of a request under paragraph 4, a revenue claim

1084of the first-mentioned State in respect of which that State may,

1085under its laws, take measures of conservancy with a view to

1086ensure its collection

1087the competent authority of the first-mentioned State shall

1088promptly notify the competent authority of the other State of

1089that fact and, at the option of the other State, the

1090first-mentioned State shall either suspend or withdraw its

1091request.

10928. In no case shall the provisions of this Article be

1093construed so as to impose on a Contracting State the

1094obligation:

1095a) to carry out administrative measures at variance with the

1096laws and administrative practice of that or of the other

1097Contracting State;

1098b) to carry out measures which would be contrary to public

1099policy (ordre public);

1100c) to provide assistance if the other Contracting State has

1101not pursued all reasonable measures of collection or conservancy,

1102as the case may be, available under its laws or administrative

1103practice;

1104d) to provide assistance in those cases where the

1105administrative burden for that State is clearly disproportionate

1106to the benefit to be derived by the other Contracting State.

1107Article 27

1108Members of diplomatic missions and consular posts

1109Nothing in this Convention shall affect the fiscal privileges

1110of members of diplomatic missions or consular posts under the

1111general rules of international law or under the provisions of

1112special agreements.

1113Article 28

1114Entitlement to benefits

11151. Notwithstanding the other provisions of this Convention, a

1116benefit under this Convention shall not be granted in respect of

1117an item of income or capital if it is reasonable to conclude,

1118having regard to all relevant facts and circumstances, that

1119obtaining that benefit was one of the principal purposes of any

1120arrangement or transaction that resulted directly or indirectly

1121in that benefit, unless it is established that granting that

1122benefit in these circumstances would be in accordance with the

1123object and purpose of the relevant provisions of this

1124Convention.

11252. Where a benefit under this Convention is denied to a person

1126under paragraph 1, the competent authority of the Contracting

1127State that would otherwise have granted this benefit shall

1128nevertheless treat that person as being entitled to this benefit,

1129or to different benefits with respect to a specific item of

1130income or capital, if such competent authority, upon request from

1131that person and after consideration of the relevant facts and

1132circumstances, determines that such benefits would have been

1133granted to that person in the absence of the transaction or

1134arrangement referred to in paragraph 1. The competent authority

1135of the Contracting State to which the request has been made will

1136consult with the competent authority of that other Contracting

1137State before rejecting a request made under this paragraph by a

1138resident of that other State.

1139Article 29

1140Protocol

1141The attached Protocol shall be an integral part of this

1142Convention.

1143Article 30

1144Entry into force

11451. The Contracting States shall notify each other in writing,

1146through diplomatic channels, when the constitutional requirements

1147for the entry into force of this Convention have been complied

1148with. This Convention shall enter into force 15 days after the

1149date of receipt of the last notification.

11502. This Convention shall have effect in both Contracting

1151States:

1152a) in respect of taxes withheld at source, on income derived

1153on or after the first day of January of the calendar year next

1154following the year in which the Convention enters into force;

1155b) in respect of other taxes on income and taxes on capital,

1156for taxes chargeable for any taxable period beginning on or after

1157the first day of January of the calendar year next following the

1158year in which the Convention enters into force.

1159Article 31

1160Termination

1161This Convention shall remain in force until terminated by a

1162Contracting State. Either Contracting State may terminate the

1163Convention, through diplomatic channels, by giving written notice

1164of termination at least six months before the end of any calendar

1165year following the fifth year after the entry into force. In such

1166event, the Convention shall cease to have effect in both

1167Contracting States:

1168a) in respect of taxes withheld at source, on income derived

1169on or after the first day of January of the calendar year next

1170following the year in which the notice has been given;

1171b) in respect of other taxes on income and taxes on capital,

1172for taxes chargeable for any taxable period beginning on or after

1173the first day of January of the calendar year next following the

1174year in which the notice has been given.

1175IN WITNESS WHEREOF the undersigned, duly authorised thereto,

1176have signed this Convention.

1177DONE in duplicate at Copenhagen this 2nd day of October, 2025,

1178in the Latvian, German and English languages, all three texts

1179being equally authentic. In the case of divergence of

1180interpretation the English text shall prevail.

1181For the Government of the Republic of Latvia

1182Evika Siliņa

1183For the Government of the Principality of

1184Liechtenstein

1185Brigitte Haas

1186Protocol

1187At the signing today of the Convention between the Government

1188of the Republic of Latvia and the Government of the Principality

1189of Liechtenstein for the elimination of double taxation with

1190respect to taxes on income and on capital and the prevention of

1191tax evasion and avoidance, the undersigned have agreed that the

1192following provisions shall form an integral part of the

1193Convention.

11941. With reference to Article 2 (Taxes covered) and Article 22

1195(Elimination of double taxation):

1196It is understood that if a person who is a resident of a

1197Contracting State is in accordance with this Convention subject

1198to Liechtenstein wealth tax on capital, the taxation of the

1199notional income on such capital ("Sollertrag") is

1200considered as personal income tax.

12012. With reference to sub-paragraph c) of paragraph 1 of

1202Article 3 (General definitions):

1203lt is understood that the term "person" includes a

1204Liechtenstein dormant inheritance. A Liechtenstein dormant

1205inheritance is the wealth of a deceased person during the period

1206between the time of death and the transfer of ownership to the

1207successor(s) as taxable under paragraph 3 of Article 7 of the

1208Liechtenstein Tax Act.

12093. With reference to sub-paragraph k) of paragraph 1 of

1210Article 3 (General definitions):

1211It is understood that the term "recognised pension

1212fund" includes the following:

1213a) in Latvia, any pension fund or scheme covered by the Law on

1214State Pensions, the Law on State Funded Pensions and the Private

1215Pension Fund Law, an investment management company managing funds

1216of investment plans of state funded pension schemes and the funds

1217invested by such companies;

1218b) in Liechtenstein, any pension fund or scheme covered by the

1219Law on Old Age and Survivors' Insurance, the Law on Disability

1220Insurance, the Law on Occupational Pension Funds, and the Pension

1221Fund Act.

12224. With reference to paragraph 1 of Article 4 (Resident):

1223It is understood that:

1224a) a Liechtenstein foundation ("Stiftung"), an

1225establishment ("Anstalt"), and a trust enterprise

1226("Treuunternehmen mit Persönlichkeit") taxable in

1227Liechtenstein by virtue of paragraph 1 of Article 44 of the

1228Liechtenstein Tax Act is considered as resident in

1229Liechtenstein;

1230b) a Liechtenstein trust taxable in Liechtenstein by virtue of

1231Article 65 of the Liechtenstein Tax Act is not considered as

1232resident in Liechtenstein;

1233c) an entity or organisation that is established and is

1234operated exclusively for charitable, religious, humanitarian,

1235scientific, cultural, or similar purposes (or for more than one

1236of those purposes) and that is established in or a resident of

1237that State according to its laws is considered as resident of

1238that State, notwithstanding that all or part of its income or

1239gains may be exempt from tax under the domestic law of that

1240State.

12415. With reference to paragraph 1 of Article 4 (Resident) and

1242Article 15 (Directors' fees):

1243It is understood that, except for the purpose of Article 15,

1244persons (including private asset structures under Liechtenstein

1245law) that are subject in Liechtenstein only to the minimum

1246corporate income tax ("Mindestertragssteuer") are not

1247considered residents of Liechtenstein.

12486. With reference to Article 7 (Business profits):

1249a) Paragraphs 1 to 7 of Article 7 of the Convention shall be

1250deleted and replaced by the following provisions on the date to

1251be agreed between the Governments of the Contracting States

1252through an exchange of diplomatic notes:

1253"1. Profits of an enterprise of a Contracting State shall

1254be taxable only in that State unless the enterprise carries on

1255business in the other Contracting State through a permanent

1256establishment situated therein. If the enterprise carries on

1257business as aforesaid, the profits that are attributable to the

1258permanent establishment in accordance with the provisions of

1259paragraph 2 may be taxed in that other State.

12602. For the purposes of this Article and Article 22, the

1261profits that are attributable in each Contracting State to the

1262permanent establishment referred to in paragraph 1 are the

1263profits it might be expected to make, in particular in its

1264dealings with other parts of the enterprise, if it were a

1265separate and independent enterprise engaged in the same or

1266similar activities under the same or similar conditions, taking

1267into account the functions performed, assets used and risks

1268assumed by the enterprise through the permanent establishment and

1269through the other parts of the enterprise.

12703. Where, in accordance with paragraph 2, a Contracting State

1271adjusts the profits that are attributable to a permanent

1272establishment of an enterprise of one of the Contracting States

1273and taxes accordingly profits of the enterprise that have been

1274charged to tax in the other State, the other State shall, to the

1275extent necessary to eliminate double taxation on these profits,

1276make an appropriate adjustment to the amount of the tax charged

1277on those profits. In determining such adjustment, the competent

1278authorities of the Contracting States shall if necessary consult

1279each other.

12804. Where profits include items of income which are dealt with

1281separately in other Articles of this Convention, then the

1282provisions of those Articles shall not be affected by the

1283provisions of this Article.".

1284b) The provisions of paragraphs 1 to 4 of Article 7 of the

1285Convention as amended by the provisions of sub-paragraph a) shall

1286have effect with respect to profits of an enterprise for any

1287taxable periods beginning on or after the date referred to in

1288sub-paragraph a). Until the provisions of paragraphs 1 to 4 of

1289Article 7 of the Convention as amended by the provisions of

1290sub-paragraph a) have effect, the provisions of the original

1291paragraphs 1 to 7 of Article 7 of the Convention shall continue

1292to apply.

12937. With reference to Article 25 (Exchange of information):

1294It is understood that for the purposes of the Convention

1295that:

1296a) the information exchanged must not be disclosed to any

1297other State or sovereign territory not party to this

1298Convention;

1299b) personal data may be processed and transmitted to the

1300extent necessary for the exchange of information according to

1301Article 25;

1302c) any request for information shall be in writing;

1303d) it has effect for requests made on or after 1 January of

1304the calendar year next following the year in which this

1305Convention enters into force and only in respect of taxable

1306periods beginning on or after 1 January of the calendar year next

1307following the year in which this Convention enters into

1308force;

1309e) in case of termination of the Convention according to

1310Article 31 the confidentiality provisions as outlined in

1311paragraph 2 of Article 25 with respect to any information

1312obtained under this Convention shall continue to apply;

1313f) the entry into force of this Convention does not preclude

1314the Contracting States from applying the provisions of the

1315Agreement of 7 December 2004 between the European Community and

1316the Principality of Liechtenstein providing for measures

1317equivalent to those laid down in Council Directive 2003/48/EC on

1318taxation of savings income in the form of interest payments, as

1319amended by the Amending Protocol of 28 October 2015 thereto, or

1320the Convention on Mutual Administrative Assistance in Tax

1321Matters, as amended by the Protocol amending the Convention on

1322Mutual Administrative Assistance in Tax Matters.

1323IN WITNESS WHEREOF the undersigned, duly authorised thereto,

1324have signed this Protocol.

1325DONE in duplicate at Copenhagen this 2nd day of October, 2025,

1326in the Latvian, German and English languages, all three texts

1327being equally authentic. In the case of divergence of

1328interpretation the English text shall prevail.

1329For the

1330Government of the Republic of Latvia

1331Evika Siliņa

1332For the

1333Government of the Principality of Liechtenstein

1334Brigitte Haas