CONVENTION BETWEEN

Termination 1.  This Agreement shall remain in force indefinitely but either of the Contracting States may terminate this Agreement through the diplomatic channel, by giving to the other Contracting State written notice of termination not later than 30 June of any calendar year starting five years after the year in which this Agreement entered into force. 2.  In such event this Agreement shall cease to have effect: a)  with regard to taxes withheld at source, in respect of amounts paid or credited after the end of the calendar year in which such notice is given; and b)  with regard to other taxes, in respect of taxable years beginning after the end of the calendar year in which such notice is given. In witness whereof the undersigned, being duly authorized thereto, have signed this Agreement. Done in duplicate at Riyadh, on 14th March 2018 corresponding to 26th Jumada›II 1439H, in the Arabic, Georgian and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For The Kingdom Of Saudi Arabia Mohammad Abdullah Al-Jadaan Minister of Finance For Georgia Mamuka Bakhtadze Minister of Finance PROTOCOL At the moment of signing the “Agreement between the Kingdom of Saudi Arabia and Georgia for the Avoidance of double taxation with respect to taxes on income and on capital and the prevention of tax evasion”, the undersigned have agreed that the following provisions shall form an integral part of the Agreement. 1.  With reference to Article 3 of the Agreement: In the case of Georgia, the term “administrative subdivisions” or ”local authorities” means, “administrative-territorial units” or “local self-governing authorities”; 2.  With reference to Article 7 of the Agreement: It is understood that: a)  the business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on through a permanent establishment in the other Contracting State, profits derived from such activities may be taxed in the other Contracting State; b)  The term “business profits” includes, but is not limited to profits derived from manufacturing, mercantile, banking, insurance, the operation of inland transportation and the furnishing of services. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity. In witness whereof the undersigned, being duly authorized thereto, have signed this Protocol. Done in duplicate at Riyadh ,on 14th March 2018 corresponding to 26th Jumada›II 1439H, in the Arabic, Georgian and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For The Kingdom Of Saudi Arabia Mohammad Abdullah Al-Jadaan Minister of Finance For Georgia Mamuka Bakhtadze Minister of Finance