THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA ON AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF TAX AVOIDANCE CONCERNING TAXES ON THE INCOME AND PROPERTY

of December 23, 1994

The government of the Republic of Belarus and the Government of the Republic of Moldova which are hereinafter referred to as with Contracting States

wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and property, agreed about the following:

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 or property value or on income elements, including the non-personal taxes, taxes on the income from property acquisition and tax on the wages amount paid by the company are considered as taxes on the income and property.

3. Taxes to which this agreement extends, in particular, are:

a) in Belarus:

tax on the income and profit of legal entities,

the income tax from citizens,

real estate tax (further "the Belarusian tax");

b) in Moldova:

income tax (income) of the companies,

the income tax from physical persons,

non-personal tax (further "the Moldavian tax").

4. This agreement is applied also to any to taxes identical or similar in essence which are levied in addition to the existing taxes or instead of them, after signature date of this agreement. Competent authorities of Contracting States inform each other on any essential changes taking place in their tax legislations.

5. For the purposes of this agreement the penalties levied from the taxpayer in case of violation of the tax legislation or tax avoidance and also the percent levied in connection with payment delay are not considered as taxes.

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