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AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF THE REPUBLIC OF FINLAND

of December 18, 2007

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

The government of the Republic of Belarus and the Government of the Republic of Finland, wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income, agreed as follows:

Article 1. Persons to whom the Agreement is applied

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

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to the taxes on the income levied on behalf of the Contracting State or its regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from income elements 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 taxes on the income from increase in capital value are considered as taxes on the income.

3. The existing taxes to which the Agreement extends are:

a) in Belarus:

(i) tax on the income and profit;

(ii) the income tax from physical persons; and

(iii) real estate tax

(further - the Belarusian tax);

b) in Finland:

(i) national income taxes (valtion tuloverot; de statliga inkomstskatterna);

(ii) corporate income tax (yhteisoejen tulovero; inkomstskatten foer samfund);

(iii) municipal tax (kunnallisvero; kommunalskatten);

(iv) church rate (kirkollisvero; kyrkoskatten);

(v) the tax on percent levied at source (korkotulon laehdevero; kaellskatten pa raenteinkomst); and

(vi) the tax on the income of nonresidents levied at source (rajoitetusti verovelvollisen laehdevero; kaellskatten foer begraensat skattskyldig) (further - the Finnish tax).

4. This agreement extends also to any identical or in essence similar taxes which are levied after signature date of this agreement in addition to the existing taxes or instead of them. 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 "Belarus" means the Republic of Belarus and when using in geographical sense - the territory which is under sovereignty of the Republic of Belarus and which according to the legislation of Belarus and international law is under jurisdiction of the Republic of Belarus;

b) the term "Finland" means the Republic of Finland and when using in geographical sense means the territory of the Republic of Finland and any area adjacent to territorial waters of the Republic of Finland in which according to the legislation of Finland and international law Finland can perform the rights on investigation and use of natural resources of seabed, its subsoil and waters;

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

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

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

f) 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;

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

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

(ii) any legal entity, partnership or association receiving the status as such by the legislation existing in this Contracting State;

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

i) the term means "competent authority":

(i) in Belarus - the Ministry of Taxes and Tax Collection of the Republic of Belarus or his plenipotentiary;

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