31. pants

Darbības izbeigšana

Šī konvencija ir spēkā tik ilgi, kamēr viena Līgumslēdzēja

Valsts izbeidz tā darbību. Katra Līgumslēdzēja Valsts var izbeigt

konvencijas darbību, pa diplomātiskajiem kanāliem iesniedzot

rakstisku paziņojumu par izbeigšanu vismaz sešus mēnešus pirms

jebkura kalendārā gada beigām, kas seko piektajam gadam pēc

stāšanās spēkā. Šajā gadījumā konvencija zaudē spēku abās

Līgumslēdzējās Valstīs:

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

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

kalendārajā gadā, kas seko gadam, kurā ir iesniegts

paziņojums;

b) attiecībā uz pārējiem ienākuma un kapitāla nodokļiem -

nodokļiem, kas maksājami par jebkuru taksācijas periodu, kas

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

seko gadam, kurā ir iesniegts paziņojums.

To apliecinot, būdami pienācīgi pilnvaroti, šo konvenciju ir

parakstījuši.

Parakstīts Kopenhāgenā 2025. gada 2. oktobrī divos eksemplāros

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

vienlīdz autentiski. Atšķirīgas interpretācijas gadījumā

noteicošais ir teksts angļu valodā.

Latvijas Republikas valdības vārdā

Evika Siliņa

Lihtenšteinas Firstistes valdības vārdā

Brigite Hāsa

Protokols

Šodien, parakstot Latvijas Republikas valdības un

Lihtenšteinas Firstistes valdības konvenciju par nodokļu dubultās

uzlikšanas attiecībā uz ienākuma un kapitāla nodokļiem un par

ļaunprātīgas izvairīšanās no nodokļu maksāšanas un nodokļu

nemaksāšanas novēršanu apakšā parakstījušies vienojas, ka šādi

noteikumi ir konvencijas neatņemama sastāvdaļa.

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

konvencija) un 22. pantu (Nodokļu dubultās uzlikšanas

novēršana):

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

rezidents, saskaņā ar šo konvenciju ir uzliekams Lihtenšteinas

īpašuma nodoklis kapitālam, nodokli, ko uzliek nosacītajam

ienākumam no šāda kapitāla ("Sollertrag"),

uzskata par iedzīvotāju ienākuma nodokli.

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

punktu:

Tiek saprasts, ka termins "persona" ietver

Lihtenšteinā neaktivizētu mantojumu. Lihtenšteinā neaktivizēts

mantojums ir mirušās personas īpašums laika posmā no nāves brīža

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

Lihtenšteinas Nodokļu likuma 7. panta 3. daļu piemēro

nodokli.

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

punktu:

Tiek saprasts, ka termins "atzīts pensiju fonds"

ietver:

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

likums "Par valsts pensijām", Valsts fondēto pensiju

likums un Privāto pensiju fondu likums, ieguldījumu pārvaldes

sabiedrību, kas pārvalda valsts fondēto pensiju shēmu ieguldījumu

plānu līdzekļus un šādu sabiedrību ieguldītos līdzekļus;

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

attiecas Likums par vecuma un apgādnieka zaudējuma apdrošināšanu,

Likums par invaliditātes apdrošināšanu, Likums par arodu pensiju

fondiem un Pensiju fondu likums.

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

Tiek saprasts, ka:

a) Lihtenšteinas fondu ("Stiftung"),

nodibinājumu ("Anstalt") un trasta uzņēmumu

("Treuunternehmen mit Persönlichkeit"), kam

nodoklis uzliekams Lihtenšteinā saskaņā ar Lihtenšteinas Nodokļu

likuma 44. panta 1. daļu, uzskata par Lihtenšteinas

rezidentu;

b) Lihtenšteinas trastu, kam nodoklis uzliekams Lihtenšteinā

saskaņā ar Lihtenšteinas Nodokļu likuma 65. pantu, neuzskata par

Lihtenšteinas rezidentu;

c) vienību vai organizāciju, kas nodibināta un darbojas

vienīgi labdarības, reliģiskiem, humānās palīdzības,

zinātniskiem, kultūras vai līdzīgiem mērķiem (vai vairākiem no

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

saskaņā ar tās normatīvajiem aktiem, uzskata par šīs valsts

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

kapitāla pieauguma var atbrīvot no nodokļa uzlikšanas saskaņā ar

šīs valsts normatīvajiem aktiem.

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

(Direktoru atalgojums):

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

(tostarp privāto aktīvu struktūras saskaņā ar Lihtenšteinas

normatīvajiem aktiem), kurām Lihtenšteinā piemērojams tikai

minimālais uzņēmumu ienākuma nodoklis

("Mindestertragssteuer") neuzskata par

Lihtenšteinas rezidentiem.

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

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

šādiem noteikumiem datumā, par kuru vienojas Līgumslēdzēju Valstu

valdības, apmainoties ar diplomātiskajām notām:

"1. Līgumslēdzējas Valsts uzņēmuma peļņai tiek uzlikti

nodokļi tikai šajā valstī, izņemot, ja uzņēmums veic

uzņēmējdarbību otrā Līgumslēdzējā Valstī, izmantojot tur esošu

pastāvīgo pārstāvniecību. Ja uzņēmums veic uzņēmējdarbību

minētajā veidā, uzņēmuma peļņai, kas attiecināma uz šo pastāvīgo

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

valstī.

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

Līgumslēdzējā Valstī attiecināma uz 1. daļā minēto pastāvīgo

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

darījumos ar citām uzņēmuma daļām, ja tā būtu atsevišķs un

neatkarīgs uzņēmums, kas veic tādu pašu vai līdzīgu

uzņēmējdarbību tādos pašos vai līdzīgos apstākļos, ņemot vērā

uzņēmuma veiktās funkcijas, izmantotos aktīvus un uzņemtos

riskus, izmantojot pastāvīgo pārstāvniecību un citas uzņēmuma

daļas.

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

kas ir attiecināma uz vienas Līgumslēdzējas Valsts uzņēmuma

pastāvīgo pārstāvniecību, un attiecīgi uzliek nodokļus uzņēmuma

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

apmērā, cik nepieciešams novērst nodokļu dubulto uzlikšanu šai

peļņai, veic atbilstošu šai peļņai uzliktā nodokļa summas

korekciju. Nosakot šādu korekciju, Līgumslēdzēju Valstu

kompetentās iestādes nepieciešamības gadījumā savstarpēji

konsultējas.

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

citos šīs konvencijas pantos, šā panta noteikumi neietekmē šo

citu pantu noteikumus.".

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

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

jebkuriem taksācijas periodiem, kas sākas a) punktā minētajā

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

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

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

noteikumus.

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

Tiek saprasts, ka šīs konvencijas mērķiem:

a) informāciju, ar kuru apmainās, nedrīkst izpaust nevienai

citai valstij vai suverēnai teritorijai, kas nav šīs konvencijas

līgumslēdzēja puse;

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

tas nepieciešams informācijas apmaiņai saskaņā ar 25. pantu;

c) jebkurš informācijas pieprasījums tiek veikts

rakstiski;

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

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

konvencija stājas spēkā, un tikai attiecībā uz taksācijas

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

seko gadam, kurā šī konvencija stājas spēkā;

e) gadījumā, ja konvencijas darbība tiek izbeigta saskaņā ar

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

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

konfidencialitātes noteikumus;

f) šīs konvencijas spēkā stāšanās neliedz Līgumslēdzējām

Valstīm piemērot 2004. gada 7. decembra Nolīguma starp Eiropas

Kopienu un Lihtenšteinas Firstisti, ar ko nosaka līdzvērtīgus

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

procentu ienākumu no uzkrājumiem aplikšanu ar nodokli, kas

grozīts ar 2015. gada 28. oktobra grozījumu protokolu,

noteikumus, vai Konvenciju par savstarpējo administratīvo

palīdzību nodokļu jautājumos, kas grozīta ar protokolu, ar ko

groza Konvenciju par savstarpējo administratīvo palīdzību nodokļu

jautājumos.

To apliecinot, būdami pienācīgi pilnvaroti, šo konvenciju ir

parakstījuši.

Parakstīts Kopenhāgenā 2025. gada 2. oktobrī divos eksemplāros

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

vienlīdz autentiski. Atšķirīgas interpretācijas gadījumā

noteicošais ir teksts angļu valodā.

Latvijas Republikas valdības vārdā

Evika Siliņa

Lihtenšteinas Firstistes valdības vārdā

Brigite Hāsa

Convention

between the Government of the Republic of Latvia and the

Government of the Principality of Liechtenstein for the

elimination of double taxation with respect to taxes on income

and on capital and the prevention of tax evasion and

avoidance

The Government of the Republic of Latvia and the Government of

the Principality of Liechtenstein,

Desiring to further develop their economic relationship and to

enhance their co-operation in tax matters,

Intending to conclude a Convention for the elimination of

double taxation with respect to taxes on income and on capital

without creating opportunities for non-taxation or reduced

taxation through tax evasion or avoidance (including through

treaty-shopping arrangements aimed at obtaining reliefs provided

in this Convention for the indirect benefit of residents of third

States),

Have agreed as follows:

Article 1

Persons covered

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

one or both of the Contracting States.

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

through an entity or arrangement that is treated as wholly or

partly fiscally transparent under the tax law of either

Contracting State shall be considered to be income of a resident

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

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

a resident of that State.

Article 2

Taxes covered

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

capital 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 and on capital

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

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

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

on capital appreciation.

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

in particular:

a) in Latvia:

(i) the enterprise income tax (uzņēmumu ienākuma

nodoklis);

(ii) the personal income tax (iedzīvotāju ienākuma

nodoklis);

(iii) the immovable property tax (nekustamā īpašuma

nodoklis);

(hereinafter referred to as "Latvian tax");

b) in Liechtenstein:

(i) the personal income tax (Erwerbssteuer);

(ii) the corporate income tax (Ertragssteuer);

(iii) the real estate capital gains tax

(Grundstücksgewinnsteuer); and

(iv) the wealth tax (Vermögenssteuer)

(hereinafter referred to as "Liechtenstein

tax").

4. The Convention shall apply also to any identical or

substantially similar taxes that are imposed after the date of

signature of the Convention 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 Convention, unless the context

otherwise requires:

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

other Contracting State" mean the Republic of Latvia or the

Principality of Liechtenstein as the context requires;

b) (i) 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;

(ii) the term "Liechtenstein" means the Principality

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

area of the sovereign territory of the Principality of

Liechtenstein in accordance with international law and its

domestic laws;

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

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

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

any entity that is treated as a body corporate for tax

purposes;

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

of any business;

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 Latvia, the Ministry of Finance or its authorised

representative;

(ii) in Liechtenstein, the Fiscal Authority;

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

State, means:

(i) any individual possessing the nationality or citizenship

of that Contracting State; and

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

status as such from the laws in force in that Contracting

State;

j) the term "business" includes the performance of

professional services and of other activities of an independent

character;

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

means an entity or arrangement established in that State that is

treated as a separate person under the taxation laws of that

State and:

(i) that is established and operated exclusively or almost

exclusively to administer or provide retirement benefits and

ancillary or incidental benefits to individuals and that is

regulated as such by that State or one of its political

subdivisions or local authorities; or

(ii) that is established and operated exclusively or almost

exclusively to invest funds for the benefit of entities or

arrangements referred to in subdivision (i).

2. As regards the application of the Convention 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 Convention 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 Convention, the term

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

under the laws of that State, 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 that State and any political subdivision or local

authority thereof as well as a recognised pension fund of that

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

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

sources in that State or capital situated therein.

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 he is a national of both States or of neither of them,

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 determine by mutual agreement the Contracting State

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

purposes of the Convention, having regard to its place of

effective management, the place where it is incorporated or

otherwise constituted and any other relevant factors. In the

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

any relief or exemption from tax provided by this Convention

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

the competent authorities of the Contracting States.

Article 5

Permanent establishment

1. For the purposes of this Convention, 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; and

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

extraction of natural resources.

3. The term "permanent establishment" also

includes:

a) a building site, construction, assembly or installation

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

b) activities carried on offshore in a Contracting State in

connection with the exploration or exploitation of the sea bed

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

if such activities are carried on for a period or periods

exceeding in the aggregate 30 days in any twelve month period

commencing or ending in the taxable period concerned.

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 but

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

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

doing so, habitually concludes contracts, or habitually plays the

principal role leading to the conclusion of contracts that are

routinely concluded without material modification by the

enterprise, and these contracts are:

a) in the name of the enterprise, or

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

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

the enterprise has the right to use, or

c) for the provision of services by that 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.

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

the income from immovable property of an enterprise.

Article 7

Business profits

1. 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 (other than expenses which would not be deductible if

that permanent establishment were a separate enterprise of that

Contracting State) 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.

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 Convention, then the

provisions of those Articles shall not be affected by the

provisions of this Article.

Article 8

International 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. 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. In determining such adjustment, due regard

shall be had to the other provisions of this Convention 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 per cent of the gross amount of the dividends if the

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

b) 10 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. The term "dividends" as used in this Article

means income from shares, "jouissance" shares or

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

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

well as income from other 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.

4. The provisions of paragraph 1 and 2 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 and the

holding in respect of which the dividends are paid is effectively

connected with such permanent establishment. In such case the

provisions of Article 7 shall apply.

5. 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 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 per cent of the gross amount of the interest if the

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

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

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

interest;

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

other cases.

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

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

the other Contracting State or to a political subdivision or

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

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

taxable only in that other State.

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

Article 10. Penalty charges for late payment shall not be

regarded as interest for the purpose of this Article.

5. The provisions of paragraph 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 and the debt-claim in respect of

which the interest is paid is effectively connected with such

permanent establishment. In such case the provisions of Article 7

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 in connection with which the indebtedness on which

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

such permanent establishment, then such interest shall be deemed

to arise in the State in which the permanent establishment 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 Convention.

Article 12

Royalties

1. Royalties arising in a Contracting State and beneficially

owned by 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:

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

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

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

a resident of the other Contracting State and is the beneficial

owner of the royalties;

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

other cases.

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 or

tapes 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 and the right or property in

respect of which the royalties are paid is effectively connected

with such permanent establishment. In such case the provisions of

Article 7 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 in connection with which the liability to pay the

royalties was incurred, and such royalties are borne by such

permanent establishment, then such royalties shall be deemed to

arise in the State in which the permanent establishment 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

Convention.

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 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, including such gains from the alienation of such a

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

be taxed in that other State.

3. Gains that an enterprise of a Contracting State that

operates ships or aircraft in international traffic derives from

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

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

taxable only in that State.

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

alienation of shares or comparable interests, such as interests

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

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

alienation, these shares or comparable interests derived more

than 50 per cent of their value directly or indirectly from

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

other 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

Income from employment

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

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 days in any twelve

month period commencing or ending in the fiscal 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

which the employer has in the other State.

3. Notwithstanding the preceding provisions of this Article,

remuneration derived by a resident of a Contracting State in

respect of an employment exercised aboard a ship or aircraft

operated in international traffic by an enterprise of the other

Contracting State may be taxed in that State.

Article 15

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 16

Entertainers and sportspersons

1. Notwithstanding the provisions of Articles 7 and 14, 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 that resident's

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 acting as such accrues not to

the entertainer or sportsperson but to another person, that

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

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

entertainer or sportsperson are exercised.

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

income derived from activities exercised in a Contracting State

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

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

Contracting States or political subdivisions or local authorities

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

taxable only in the Contracting State in which the entertainer or

the sportsperson is a resident.

Article 17

Pensions

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

pensions and other similar remuneration (including lump-sum

payments) 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 18, pensions and other similar

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

security system of a Contracting State may be taxed in that

State.

Article 18

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 State and the individual is

a resident of that State who:

(i) is a national of that State; or

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

purpose of rendering the services.

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

lump-sum payments) 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 pensions and other similar remuneration

(including lump-sum payments) 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 14, 15, 16, and 17 shall apply

to salaries, wages, pensions, and other similar remuneration

(including lump-sum payments) 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 19

Students

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.

Article 20

Other income

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

wherever arising, not dealt with in the foregoing Articles of

this Convention 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 and the right or property in respect of which the income

is paid is effectively connected with such permanent

establishment. In such case the provisions of Article 7 shall

apply.

Article 21

Capital

1. Capital represented by immovable property referred to in

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

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

other State.

2. Capital represented by 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 may be taxed in that other State.

3. Capital represented by ships and aircraft operated in

international traffic by an enterprise of a Contracting State and

by movable property pertaining to the operation of such ships or

aircraft, shall be taxable only in that State.

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

Contracting State shall be taxable only in that State.

Article 22

Elimination of double taxation

1. In Latvia, double taxation shall be eliminated as

follows:

Where a resident of Latvia derives income or owns capital

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

Liechtenstein, unless a more favourable treatment is provided in

its domestic law, Latvia shall allow:

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

an amount equal to the income tax paid thereon in

Liechtenstein;

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

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

Liechtenstein.

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

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

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

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

Liechtenstein.

2. Subject to the provisions of the laws of Liechtenstein

regarding the elimination of double taxation, which shall not

affect the general principle hereof, double taxation shall be

eliminated as follows:

a) Where a resident of Liechtenstein derives income or owns

capital which, in accordance with the provisions of this

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

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

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

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

into account the exempted income or capital.

b) Where a resident of Liechtenstein derives items of income

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

14, 15, 16, and 17, may be taxed in Latvia, Liechtenstein shall

credit against the Liechtenstein tax on this income the tax paid

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

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

however, exceed the Liechtenstein tax due on the income derived

from Latvia.

c) Where a resident of Liechtenstein derives items of income

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

Convention, shall be taxable only in Latvia, Liechtenstein shall

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

calculating the amount of tax on the remaining income or capital

of such resident, take into account the exempted income or

capital.

Article 23

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.

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

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

determining the taxable capital of such enterprise, be deductible

under the same conditions as if they had been contracted 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.

Article 24

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 Convention, he may,

irrespective of the remedies provided by the domestic law of

those States, present his case to the competent authority of

either Contracting State. The case must be presented within three

years from the first notification of the action resulting in

taxation not in accordance with the provisions of the

Convention.

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 Convention. 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

Convention. They may also consult together for the elimination of

double taxation in cases not provided for in the Convention.

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 25

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 Convention 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 Convention. 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. Notwithstanding the foregoing, information

received by a Contracting State may be used for other purposes

when such information may be used for such other purposes under

the laws of both States and the competent authority of the

supplying State authorises such use.

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 (ordre 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 26

Assistance in the collection of taxes

1. The Contracting States shall lend assistance to each other

in the collection of revenue claims. This assistance is not

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

Contracting States may by mutual agreement settle the mode of

application of this Article.

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

means an amount owed in respect of 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 this Convention or any

other instrument to which the Contracting States are parties, as

well as interest, administrative penalties and costs of

collection or conservancy related to such amount.

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

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

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

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

competent authority of that State, be accepted for purposes of

collection by the competent authority of the other Contracting

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

in accordance with the provisions of its laws applicable to the

enforcement and collection of its own taxes as if the revenue

claim were a revenue claim of that other State.

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

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

conservancy with a view to ensure its collection, that revenue

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

State, be accepted for purposes of taking measures of conservancy

by the competent authority of the other Contracting State. That

other State shall take measures of conservancy in respect of that

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

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

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

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

person who has a right to prevent its collection.

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

revenue claim accepted by a Contracting State for purposes of

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

limits or accorded any priority applicable to a revenue claim

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

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

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

priority applicable to that revenue claim under the laws of the

other Contracting State.

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

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

brought before the courts or administrative bodies of the other

Contracting State.

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

Contracting State under paragraph 3 or 4 and before the other

Contracting State has collected and remitted the relevant revenue

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

ceases to be

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

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

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

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

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

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

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

ensure its collection

the competent authority of the first-mentioned State shall

promptly notify the competent authority of the other State of

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

first-mentioned State shall either suspend or withdraw its

request.

8. In no case shall the provisions of this Article 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 carry out measures which would be contrary to public

policy (ordre public);

c) to provide assistance if the other Contracting State has

not pursued all reasonable measures of collection or conservancy,

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

practice;

d) to provide assistance in those cases where the

administrative burden for that State is clearly disproportionate

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

Article 27

Members of diplomatic missions and consular posts

Nothing in this Convention 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

Entitlement to benefits

1. Notwithstanding the other provisions of this Convention, a

benefit under this Convention shall not be granted in respect of

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

having regard to all relevant facts and circumstances, that

obtaining that benefit was one of the principal purposes of any

arrangement or transaction that resulted directly or indirectly

in that benefit, unless it is established that granting that

benefit in these circumstances would be in accordance with the

object and purpose of the relevant provisions of this

Convention.

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

under paragraph 1, the competent authority of the Contracting

State that would otherwise have granted this benefit shall

nevertheless treat that person as being entitled to this benefit,

or to different benefits with respect to a specific item of

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

that person and after consideration of the relevant facts and

circumstances, determines that such benefits would have been

granted to that person in the absence of the transaction or

arrangement referred to in paragraph 1. The competent authority

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

consult with the competent authority of that other Contracting

State before rejecting a request made under this paragraph by a

resident of that other State.

Article 29

Protocol

The attached Protocol shall be an integral part of this

Convention.

Article 30

Entry into force

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

through diplomatic channels, when the constitutional requirements

for the entry into force of this Convention have been complied

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

date of receipt of the last notification.

2. This Convention shall have effect in both Contracting

States:

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

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

following the year in which the Convention enters into force;

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

for taxes chargeable for any taxable period beginning on or after

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

year in which the Convention enters into force.

Article 31

Termination

This Convention shall remain in force until terminated by a

Contracting State. Either Contracting State may terminate the

Convention, through diplomatic channels, by giving written notice

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

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

event, the Convention shall cease to have effect in both

Contracting States:

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

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

following the year in which the notice has been given;

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

for taxes chargeable for any taxable period beginning on or after

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

year in which the notice has been given.

IN WITNESS WHEREOF the undersigned, duly authorised thereto,

have signed this Convention.

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

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

being equally authentic. In the case of divergence of

interpretation the English text shall prevail.

For the Government of the Republic of Latvia

Evika Siliņa

For the Government of the Principality of

Liechtenstein

Brigitte Haas

Protocol

At the signing today of the Convention between the Government

of the Republic of Latvia and the Government of the Principality

of Liechtenstein for the elimination of double taxation with

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

tax evasion and avoidance, the undersigned have agreed that the

following provisions shall form an integral part of the

Convention.

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

(Elimination of double taxation):

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

Contracting State is in accordance with this Convention subject

to Liechtenstein wealth tax on capital, the taxation of the

notional income on such capital ("Sollertrag") is

considered as personal income tax.

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

Article 3 (General definitions):

lt is understood that the term "person" includes a

Liechtenstein dormant inheritance. A Liechtenstein dormant

inheritance is the wealth of a deceased person during the period

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

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

Liechtenstein Tax Act.

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

Article 3 (General definitions):

It is understood that the term "recognised pension

fund" includes the following:

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

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

Pension Fund Law, an investment management company managing funds

of investment plans of state funded pension schemes and the funds

invested by such companies;

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

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

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

Fund Act.

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

It is understood that:

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

establishment ("Anstalt"), and a trust enterprise

("Treuunternehmen mit Persönlichkeit") taxable in

Liechtenstein by virtue of paragraph 1 of Article 44 of the

Liechtenstein Tax Act is considered as resident in

Liechtenstein;

b) a Liechtenstein trust taxable in Liechtenstein by virtue of

Article 65 of the Liechtenstein Tax Act is not considered as

resident in Liechtenstein;

c) an entity or organisation that is established and is

operated exclusively for charitable, religious, humanitarian,

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

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

that State according to its laws is considered as resident of

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

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

State.

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

Article 15 (Directors' fees):

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

persons (including private asset structures under Liechtenstein

law) that are subject in Liechtenstein only to the minimum

corporate income tax ("Mindestertragssteuer") are not

considered residents of Liechtenstein.

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

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

deleted and replaced by the following provisions on the date to

be agreed between the Governments of the Contracting States

through an exchange of diplomatic notes:

"1. 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 that are attributable to the

permanent establishment in accordance with the provisions of

paragraph 2 may be taxed in that other State.

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

profits that are attributable in each Contracting State to the

permanent establishment referred to in paragraph 1 are the

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

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

separate and independent enterprise engaged in the same or

similar activities under the same or similar conditions, taking

into account the functions performed, assets used and risks

assumed by the enterprise through the permanent establishment and

through the other parts of the enterprise.

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

adjusts the profits that are attributable to a permanent

establishment of an enterprise of one of the Contracting States

and taxes accordingly profits of the enterprise that have been

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

extent necessary to eliminate double taxation on these profits,

make an appropriate adjustment to the amount of the tax charged

on those profits. In determining such adjustment, the competent

authorities of the Contracting States shall if necessary consult

each other.

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

separately in other Articles of this Convention, then the

provisions of those Articles shall not be affected by the

provisions of this Article.".

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

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

have effect with respect to profits of an enterprise for any

taxable periods beginning on or after the date referred to in

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

Article 7 of the Convention as amended by the provisions of

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

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

to apply.

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

It is understood that for the purposes of the Convention

that:

a) the information exchanged must not be disclosed to any

other State or sovereign territory not party to this

Convention;

b) personal data may be processed and transmitted to the

extent necessary for the exchange of information according to

Article 25;

c) any request for information shall be in writing;

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

the calendar year next following the year in which this

Convention enters into force and only in respect of taxable

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

following the year in which this Convention enters into

force;

e) in case of termination of the Convention according to

Article 31 the confidentiality provisions as outlined in

paragraph 2 of Article 25 with respect to any information

obtained under this Convention shall continue to apply;

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

the Contracting States from applying the provisions of the

Agreement of 7 December 2004 between the European Community and

the Principality of Liechtenstein providing for measures

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

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

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

the Convention on Mutual Administrative Assistance in Tax

Matters, as amended by the Protocol amending the Convention on

Mutual Administrative Assistance in Tax Matters.

IN WITNESS WHEREOF the undersigned, duly authorised thereto,

have signed this Protocol.

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

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

being equally authentic. In the case of divergence of

interpretation the English text shall prevail.

For the

Government of the Republic of Latvia

Evika Siliņa

For the

Government of the Principality of Liechtenstein

Brigitte Haas