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of April 23, 2015

About avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital

Government of the Republic of Belarus and

Government of Georgia,

wishing to develop and strengthen the economic, cultural and scientific relations by means of the conclusion

Agreements on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital, agreed as follows:

Article 1. Persons to whom this agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States.

Article 2. Taxes to which this agreement extends

1. This agreement is applied to the taxes on the income and the capital levied on behalf of the Contracting State, either its political and administrative divisions, or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income, total amount of the capital or from elements of the income of pla of the capital including taxes on the income from alienation of personal or real estate, taxes on the total amount of the salary paid by the companies and also capital gain taxes are considered as taxes on the income and the capital.

3. The existing taxes to which this agreement extends are, in particular:

a) in case of Georgia:

income tax;

tax on the income;

property tax

(further - the Georgian tax);

b) in case of Belarus:

tax on the income;

income tax;

the income tax from physical persons;

real estate tax

(further - the Belarusian tax).

4. This agreement extends also to any identical or in essence similar taxes which are levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States notify each other on any essential changes made to their tax legislation.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

a) the term "Georgia" means the territory determined according to the legislation of Georgia including the land, its subsoil and airspace over them, internal waters and the territorial sea, seabed, its subsoil and airspace over them concerning which Georgia performs the jurisdiction and the sovereign rights, and also contiguous zone, exclusive economic zone and the continental shelf adjacent to its territorial sea concerning which Georgia can perform the sovereign rights and (or) jurisdiction according to international law;

b) the term "Belarus" means the Republic of Belarus and when using in geographical sense - the territory which is under sovereignty of the Republic of Belarus and according to the legislation of Belarus and international law being under jurisdiction of the Republic of Belarus;

c) the terms "one Contracting State" and "other Contracting State" mean Georgia or Belarus depending on context;

d) the term "person" means physical person, the company and any other consolidation of persons;

e) the term "company" means any legal entity or any organization which for the purposes of the taxation is considered as the separate organization;

f) the term "company" is applied to implementation by person of any business activity;

g) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

h) the term "international delivery" means any transportation sea or the aircraft operated by the company which place of the actual management is located in one Contracting State, except as specified, when sea or the aircraft is operated only between Items. located in other Contracting State;

i) the term means "competent authority":

(i) in Georgia - the Ministry of Finance or its plenipotentiary;

(ii) in Belarus - the Ministry of Taxes and Tax Collection or its plenipotentiary;

j) the term "national person" concerning the Contracting State means:

(i) any physical person having nationality of this Contracting State;


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