AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

of June 30, 2006

About avoidance of double taxation concerning taxes on the income and property

Government of the Republic of Belarus and Government of Democratic People's Republic of Korea,

wishing to sign the Agreement on avoidance of double taxation concerning taxes on the income and property and for the purpose of encouragement of economic cooperation between two countries,

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 and property levied on behalf of the Contracting State irrespective of method of their collection.

2. All taxes levied from the total amount of the income, total amount of property or from elements of the income or property including taxes on the income from alienation of personal or real estate, taxes on the total amount of the salary, and also the property increment value duties are considered as taxes on the income and property.

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

a) in Belarus:

tax on the income and profit;

the income tax from physical persons;

real estate tax

(further - the Belarusian tax);

b) in Democratic People's Republic of Korea:

tax on the income of the companies;

individual income tax;

property tax;

succession duty

(further - the tax DPRK).

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 taxes mentioned in Item 3, 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 terms "one Contracting State" and "other Contracting State" mean Belarus or Democratic People's Republic of Korea depending on context;

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 which according to the legislation of Belarus and international law is under jurisdiction of the Republic of Belarus;

c) the term "Democratic People's Republic of Korea" when using in geographical sense means the territory and internal waters and airspace concerning which it performs the sovereign rights according to the domestic legislation, and also the continental shelf and exclusive economic zone concerning which it performs jurisdiction according to the domestic legislation and international law;

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 purposes of the taxation;

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 "permanent base" means the permanent place, including office or office through which independent activities of the physical person rendering independent personal services are fully or partially performed;

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