AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF THE SULTANATE OF OMAN

of April 15, 2007

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

Government of the Republic of Belarus and Government of the Sultanate of Oman,

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

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 the capital 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, total amount of the capital or from elements of the income or the capital 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 capital gain taxes are considered as taxes on the income and the capital.

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

a) in case of the Sultanate of Oman:

(i) the tax on the income of the companies levied according to the Royal Decree No. 47/1981 with changes; and

(ii) the income tax of organizations levied according to the Royal Decree No. 77/1989 with changes

(further - Omani tax);

b) in case of Belarus:

(i) tax on the income and profit;

(ii) the income tax from physical persons;

(iii) real estate tax

(further - the Belarusian taxes).

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 existing taxes or instead of them. Competent authorities of Contracting States notify each other on any essential changes made to their corresponding tax legislation during the acceptable period of time after such changes.

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