AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF KAZAKHSTAN AND GOVERNMENT OF THE REPUBLIC OF MACEDONIA

of July 2, 2012

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

Government of the Republic of Kazakhstan and Government of the Republic of Macedonia,

wishing to sign the Agreement on avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who 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 administrative-territorial divisions, central or regional authorities irrespective of method of their collection.

2. All types of tax levied from total of income or from separate elements of the income including taxes on the income from alienation of personal or real estate, taxes levied from the total amount of salary or the salary paid by the companies are considered as taxes on the income.

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

a) in Kazakhstan:

(i) corporate income tax and

(ii) individual income tax

(further referred to as as "The Kazakhstan tax");

b) in Macedonia:

(i) the income tax from physical persons and

(ii) income tax

(further referred to as as "The Macedonian tax").

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after the date of entry into force of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in the tax legislation of the state.

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" are meant by Kazakhstan or Macedonia depending on context;

b) the term "Kazakhstan" means the Republic of Kazakhstan and when using in geographical sense the term "Kazakhstan" includes the state territory of the Republic of Kazakhstan and zone in which Kazakhstan performs the sovereign rights and jurisdiction, according to its legislation and international treaties which participant he is;

c) the term "Macedonia" means the territory of the Republic of Macedonia in which jurisdiction or the sovereign rights for the purposes of investigation, development, preserving and management of natural resources according to internal jurisdiction and international law are performed;

d) the term "national person" means:

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

(ii) any legal entity, partnership or association who received such status based on the current legislation of the Contracting State;

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

f) the term "company" means any corporate education or any organization which for the purposes of the taxation is considered as corporate education;

g) the term "business activity" includes accomplishment of professional services and other activities of independent nature;

h) the term "company" is applied to implementation of any professional activity;

i) 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;

j) the term "international delivery" means any transportation sea or the aircraft operated by the company which place of effective management is in the Contracting State, except cases when sea or the aircraft is operated only between Items in other Contracting State;

k) the term means "competent authority":

(i) in Kazakhstan: Ministry of Finance or its authorized representative;

(ii) in Macedonia: Ministry of Finance or its authorized representative.

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