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

of May 19, 2005

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

Government of the Republic of Belarus and Government of the Republic of Macedonia,

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

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 (property) 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 (property) or from elements of the income or the capital (property) 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 (property) are considered as taxes on the income and the capital (property).

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

a) in case of Belarus:

tax on the income and profit;

the income tax from physical persons;

real estate tax

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

b) in Macedonia:

income tax;

income tax;

property tax

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

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 taxes mentioned in Item 3, 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:

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