LAW OF THE REPUBLIC OF BELARUS

of November 1, 2007 No. 285-Z

About ratification of the Agreement between the Government of the Republic of Belarus and the Government of the Sultanate of Oman about avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital

Accepted by the House of Representatives on October 4, 2007

Approved by Council of the Republic on October 17, 2007

Ratify the Agreement between the Government of the Republic of Belarus and the Government of the Sultanate of Oman on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital signed in Muscat on April 15, 2007.

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.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context:

a) the term "Sultanate of Oman" means the territory of the Sultanate of Oman and islands belonging to it, including the territorial sea and any area outside the territorial sea concerning which the Sultanate of Oman according to international law and the legislation of the Sultanate of Oman can perform the sovereign rights concerning investigation and development of natural resources of seabed and subsoil and adjacent waters;

b) the term "Belarus" means the Republic of Belarus and when using in geographical sense - the territory concerning which the Republic of Belarus performs the sovereign rights and jurisdiction according to international law and the legislation of Belarus;

c) the terms "one Contracting State" and "other Contracting State" mean the Sultanate of Oman or Belarus depending on context;

d) the term "person" means physical person, the company, consolidation of persons and any other organization which is considered as taxable unit according to the existing tax legislations of Contracting States;

e) "company" means the term:

(i) in the Sultanate of Oman - any corporate consolidation or other organization which is considered as the company or corporate consolidation according to the existing tax legislation;

(ii) in Belarus - any legal entity or any organization which is considered as the separate organization for the purposes of the taxation;

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