AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF THE ARAB REPUBLIC OF EGYPT

of June 16, 1998

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

Government of the Republic of Belarus and

Government of the Arab Republic of Egypt,

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 property acquisition, taxes on the total amount of the salary paid by the companies and also capital gain taxes are considered as taxes on the income.

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

a) in the Republic of Belarus:

(і) tax on the income and profit of the companies, associations, organizations;

(іі) the income tax from citizens;

(ііі) real estate tax

(further the referred to as "Belarusian taxes");

b) in the Arab Republic of Egypt:

(і) tax on income gained from real estate (including the agricultural land tax, tax on structures);

(іі) integrated income tax;

(ііі) tax on corporate profit;

(іv) collection on development of financial resources of the state;

(v) the additional taxes levied in the form of percent to the taxes mentioned above, or otherwise

(further the referred to as "Egyptian taxes").

4. This agreement extends also to any identical or in essence similar taxes which are levied from 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 terms "one Contracting State" and "other Contracting State" mean, depending on context, Belarus or Egypt;

b) the term "Belarus" means the Republic of Belarus and when using in geographical sense means 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 "Egypt" means the Arab Republic of Egypt and when using in geographical sense the term "Egypt" includes:

(і) its territorial sea and

(іі) seabed and subsoil of the underwater areas adjoining the coast, but outside the territorial sea concerning which Egypt performs the sovereign rights according to international law for the purposes of investigation and development of natural resources of such area, however, only in that degree in what person, the property or activities to which the Agreement is applied are connected with such investigation or development;

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

e) "company" means the term:

(і) in Belarus - any legal entity or any organization which is considered as the separate organization for the tax purposes;

(іі) in Egypt - any corporate body or any organization which is considered as corporate body 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 "international delivery" means any transportation sea and the aircraft operated by the company which is resident of one Contracting State, except as specified, when sea or the aircraft is operated only between Items in other Contracting State;

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