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) utility 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).

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