Part Article 2 Taxes covered

(1)

This Agreement 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, or on elements of income, 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 this Agreement shall apply are in particular:

(a)

in the case of Georgia:

(i)

the tax on profit (income) of enterprises;

(ii)

the tax on property of enterprises;

(iii)

the tax on income of individuals; and

(iv)

the tax on property of individuals;

(hereinafter referred to as “Georgian tax”);

(b)

in the case of the United Kingdom:

(i)

the income tax;

(ii)

the corporation tax; and

(iii)

the capital gains tax;

(hereinafter referred to as “United Kingdom tax”).

(4)

This Agreement shall also apply to any identical or substantially similar taxes that are imposed by either Contracting State after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.