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

of July 2, 2012

About avoidance of double taxation and prevention of evasion from the taxation concerning taxes on the income

Government of the Republic of Kazakhstan and Government of the Republic of Macedonia,

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

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who 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 administrative-territorial divisions, central or regional authorities irrespective of method of their collection.

2. All types of tax levied from total of income or from separate elements of the income including taxes on the income from alienation of personal or real estate, taxes levied from the total amount of salary or the salary paid by the companies are considered as taxes on the income.

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

a) in Kazakhstan:

(i) corporate income tax and

(ii) individual income tax

(further referred to as as "The Kazakhstan tax");

b) in Macedonia:

(i) the income tax from physical persons and

(ii) income tax

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

4. This agreement is also applied to any identical or in essence to similar taxes which will be levied after the date of entry into force of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in the tax legislation of the state.

Article 3. General determinations

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

a) the terms "one Contracting State" and "other Contracting State" are meant by Kazakhstan or Macedonia depending on context;

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