Artikel VI

It is understood that in the case of Kazakhstan, in computing the taxes on profits and income under the laws in effect from the date of entry into effect of the Convention until June 30, 1995, an entity that is a resident of Kazakhstan with more than 30 per cent participation by residents of the Netherlands, or a permanent establishment of an enterprise of the Netherlands (subject to the provisions of Article 7), is permitted deductions for actual wages paid and for interest expenses, whether or not paid to a bank and without regard to the term of the debt. The deduction may not exceed the limitation under Kazakh tax law, as long as the limitation is not less than an arms' length rate, including in the case of interest a reasonable risk premium.