Appendix 1

Translation

Promise of the conclusion of the double tax agreement between Denmark and Georgia

We, by God's grace, the Queen of the Danes, do our thing.

The parliament has adopted the following law, and we know that the following law has been approved by Parliament's consent :

§ 1. Deal of 10. In October 2007 between the Government of the Kingdom of Denmark and the Government of Georgia to avoid double taxation and the prevention of tax evasion, as regards income taxes, may be drawn on behalf of Denmark. The agreement with the corresponding Protocol is included in Annex 1 to this Act.

Paragraph 2. The Agreement shall enter into force and apply in Denmark, in accordance with the provisions of Article 29 of the Agreement.

§ 2. The law shall enter into force on 1. July 2008.

§ 3. The law does not apply to the Faroe Islands and Greenland.

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Appendix 1

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Translation

APPOINTMENT

MEDITO

THE GOVERNMENT OF THE KINGDOM OF DENMARK AND

GOVERNMENT OF GEORGIA

FOR THE AVOIDANCE OF DOUBLE TAXATION

AND THE PREVENTION OF TAX EVASION

IN THE CASE OF INCOME TAXES,

The Government of the Kingdom of Denmark and the Government of Georgia,

promoting and strengthening economic, cultural and scientific relations by concluding an agreement to avoid double taxation and the prevention of tax evasion as regards income taxes ;

has agreed to :

ARTICLE 1

Persons covered by the Agreement

This Agreement shall apply to persons belonging to one or both of the Contracting Governments.

ARTICLE 2

Taxes covered by the Agreement

1. This agreement shall apply to taxes on income printed on behalf of a Contracting Government or by its police-administrative sub-departments or local authorities, without regard to how they are charged.

2. As taxes on income, any taxes imposed on the whole income or part of the income, including taxes on profit, or immovable property, shall be deemed to be taxable or immovable property, as well as taxes on a wealth of wealth.

3. The applicable taxes on which the Agreement shall apply shall be :

a) In Denmark :

(hereinafter referred to as ' Danish tax `).

b) In Georgia :

(hereinafter referred to as "Georgian tax").

4. This Agreement shall also apply to taxes of the same or substantially the same species which, after the signing of the Agreement, is printed as a supplement to, or rather than the taxes in force. The competent authorities of the Contracting Parties shall inform each other of significant changes made in their tax legislation.

ARTICLE 3

Common definitions

1. Except as otherwise in the context of the context, the following terms have the following terms in this Agreement :

a) whereas the terms ' a Contracting Government ` and ' the other Contracting Government ' mean Denmark or Georgia, all in accordance with the context ;

b) the term ' Denmark ` means the Kingdom of Denmark, including any area outside Denmark's territorial waters which, in accordance with international law and under Danish law, may or later have been designated as an area within which Denmark the ability to exercise sovereignty rights in the field of investigation and exploitation of natural deposits at the bottom of the sea or in its underground waters and with regard to other activities for the purpose of investigation and economic exploitation of : the area. The term does not include the Faroes and Greenland ;

c) the term ' Georgia ` means the area of the state borders of Georgia, including inland waters, inland waters and territorial waters and the airspace above, within which Georgia is exercising sovereignty, as well as the adjacent zone, the exclusive zone, the exclusive zone, the exclusive zone ; the economic zone and continental cocond, which borders on the territorial waters within which Georgia can exercise sovereignty rights in accordance with international law ;

d) Whereas the term ' person ` includes a natural person, a company and any other group of persons ;

(e) Whereas the term "company" means any legal person or entity which is treated as a legal person in fiscal matters ;

(f) the expression ' undertaking in a Contracting Government ' and ' undertaking in the other Contracting Government ` means an undertaking operated by a person resident in a Contracting Government and an undertaking operated by a person who is a person who is a person who is a person who is a person who is a person who is or is not ; is established in the other Contracting Government ;

g) Whereas the term ' international traffic ' means any transport by ship or aircraft used by an undertaking in a Contracting Government, except where the ship or the aircraft is used exclusively between sites in the other Contracting Government ;

(h) the term ' competent authority ` means :

The Treasury or his authorized representative shall be replaced by the Member State of the subject ;

(ii) in Georgia :

The Ministry of Finance or its authorised representative shall be replaced ;

i) the term "citizen" means :

2. In the case of each of the Contracting Parties, any term not defined therein shall be subject to the importance given to it at the time of the legislation of the State concerned, subject to the consistency of the Agreement, unless otherwise provided by the legislation of the Member States. The taxes applicable to the Agreement shall be subject to the prior importance of this expression in other places in the legislation of this State in the form of the tax havens used in this State.

ARTICLE 4

Tax Home

1. In this Agreement, the term ' person belonging to a Contracting Government ' means any person under the law of that State, subject to the place of residence, the seat, the seat of the seat or any other criterion, such a character, including this State and any related police-administrative subsection or local authority. However, this expression does not include a person who is taxable in this state only of income from sources in this state.

2. If a natural person, in accordance with paragraph 1 of paragraph 1 of this Article, is established in both Contracting Governments, his status shall be determined in accordance with the following rules :

a) he shall be considered only to be resident in the State where he has a permanent residence at his disposal. If he has a permanent residence at his disposal in both countries, he shall be considered to be the resident of the State with which he has the strongest personal and economic relations (the centre of his life interests) ;

b) in the event that it cannot be decided in which State he has the centre of its life interests, or if he does not have a permanent residence in any of the Member States, he shall be considered only to be the resident of the state in which he usually has a stay ;

c) if he is usually in both States or if he does not have such a residence in any of them, he shall be considered only to be the resident of the State of which he is a national ;

d) if he is a national in both States or if he is not a national of any of them, the competent authorities of the Contracting Parties shall decide the question by mutual agreement.

3. If a non-physical person, in accordance with paragraph 1 of paragraph 1 of this Article, is established in both Contracting Governments, it shall be considered only to be the resident of the State in which its true management has its seat.

Article 5

Fixed operational location

1. In this Agreement ' firm operating location ' means a regular business location by means of an undertaking ' s undertaking wholly or partially.

2. The term ' firm operating location ` shall comprise in particular :

a) a place where an undertaking is led ;

b) a branch ;

c) an office ;

d) a factory ;

(e) a workshop ; and

(f) a mine, an oil or gas source, a quarry or any other place where natural occurrences are to be extracted.

3. A building site or assembly or installation work shall be a fixed operating point only if it lasts more than six months.

4. An installation, drilling, or a ship used in the investigation of natural occurrences, is only a fixed operating facility where the business is in more than six months. The activity of an undertaking linked to another undertaking shall be deemed to have been exercised by the undertaking, which is linked to the establishment of the undertaking :

a) the substance of the latter is essentially the same as that of the latter undertaking ; and

b) are employed by the same project or the same operation ;

unless the activities concerned are carried out simultaneously. For the purposes of this paragraph, undertakings shall be deemed to be connected when the same persons, directly or indirectly, are part of the management of the control or capital of the undertakings.

Notwithstanding the previous provisions of this Article, ' regular farm ` shall not be considered to include :

a) the use of the information solely for the purposes of storage, exhibition or delivery of the goods of the undertaking ;

b) the maintenance of a stock-related undertaking solely for the purposes of storage, exhibition or extradition ;

c) the maintenance of a stock-related undertaking solely for the purpose of processing at another undertaking ;

d) the maintenance of a fixed establishment solely for the purpose of making purchases of goods or collecting information for the undertaking ;

(e) the maintenance of a fixed establishment solely for the purpose of exercising any other undertaking of preparatory or remedial activities ;

(f) maintaining a firm business location solely to exercise any combination of the activities referred to in (a) to (e), provided that the overall business of the business as a result of this combination is of preparatory or a correcting character.

6. If a person who is not such an independent representative as referred to in paragraph 7 of this Article is acting on behalf of an undertaking and in a Contracting State, this person shall exercise a power of attorney to conclude contracts in the operation of the undertaking, the name, notwithstanding the provisions of paragraph 1 and 2 of this Article, shall be deemed to have a fixed operating point of this State in respect of any undertaking which this person assumes, unless the business of this person is carried out ; restricted to such a business, as referred to in paragraph 5 of this Article, and which, if carried out by the undertaking, a firm place of business would not make this permanent place of business for a fixed operating point in accordance with the provisions of this paragraph.

7. An enterprise shall not be deemed to have a fixed operation in a Contracting Government, simply because it operates in this State by means of a mediator, Commission or any other independent representative, provided that such persons act ; within the framework of their customary business activities.

8. The fact that a company belonging to a Contracting Government shall check or be checked by a party belonging to the other Contracting Government, or which operates in this other State (whether or not engaged in the State) (whether or not it is based on the State of the Party of European Union). is carried out through a fixed operating facility or in a different way, not in itself to ensure that one company is considered to be a firm operating facility for the other.

ARTICLE 6

Income of immovable property

1. Income as a person resident in a Contracting Government acquiring real estate (including the income of land or forestry) situated in the other Contracting Government may be subject to tax in this other state.

2. The term ' immovable property ` shall be attached to the importance it has in the law of the Contracting Government where the property in question is situated. In all cases, the expression shall include accessories to immovable property, crew and tools used in land and forestry, rights on which the provisions of the civil rights of property apply shall apply, the right of use for immovable property and the right to access ; variable or flat-rate payments as remuneration for the exploitation of, or the right to use, mineral deposits, sources and other natural occurrences. Ships and planes shall not be regarded as immovable property.

3. The provisions of paragraph 1 of this Article shall apply to income derived from direct use, rental or use in any other form of real estate.

4. The provisions of paragraphs 1 and 3 of this Article shall also apply to the income of fixed property belonging to an undertaking and on the income of real estate used in the exercise of free trade.

Article 7

Deserts on business

1. Profit to be paid by an undertaking in a Contracting Government may only be taxed in this state unless the undertaking operates in the other Contracting Government by means of an established operating location. In the case of the operator of the operator, the profit of the undertaking may be taxed in the other state, but only the part thereof which may be attributed to this firm operating location.

2. If an undertaking in a Contracting Government operates in the other Contracting Government by means of a fixed operating site, unless the provisions of paragraph 3 of this Article result in another, in each Contracting Government, the provisions of paragraph 3 of this Article shall be subject to : this firm operation takes the profit which it could be expected to achieve if it had been a free and independent undertaking engaged in the same or similar undertaking on the same or similar conditions and under conditions of use, complete free relationships have done business with the operation of which is a firm operation.

3. On the establishment of a fixed operating site, it shall be permitted to deduction costs incurred for the permanent place of operation, including the general costs incurred in management and administration, whether the costs incurred in it ; state in which the fixed operating location is situated or elsewhere.

4. If it has been customary in a Contracting Government to hire the profits of a fixed operating site on the basis of a breakdown of the total profits of the undertaking between its various departments, nothing shall be carried out in paragraph 2 of this paragraph ; Article shall prevent this Contracting Government from employing the taxable profit on the basis of such a common distribution. However, the chosen distribution method must be such that the result will be in accordance with the principles laid down in this Article.

5. No profit should be carried out to a fixed operating point simply because this fixed operation has carried out the purchase of goods for the undertaking.

For the purposes of applying the preceding paragraphs in this Article, the profits carried out to the permanent farm shall be replaced by the same year, unless there is good and full reason for using a different approach.

7. If revenue includes income as referred to in other articles of this Agreement, the provisions of these other articles shall not be affected by the provisions of this Article.

ARTICLE 8

ship and air services

1. Profit to be taxed by the operation of ships or aeroplanes in international traffic can only be taxed in this state by an undertaking in a Contracting Government when operating ships or aircraft in international traffic.

2. The provisions of paragraph 1 of this Article shall also apply to profit by participating in a pool, a business community or an international operation organisation.

Article 9

Bundling Undertaking

1. If

a) an undertaking in a Contracting Government, directly or indirectly, in the management of, control of, or capital of an undertaking in the other Contracting Government, or

b) the persons directly or indirectly participate in the management, control of, or capital of both an undertaking in a Contracting Government and in the other Contracting Government,

and in some of these cases between the two undertakings, they have been agreed or set out in terms of their business or financial relations that deviate from the terms and conditions agreed between independent undertakings, may any profit which, if these conditions had not been in place, would have been attributed to one of these undertakings, but which, because of these conditions, has not been added to this, shall be taken into account by the profit of this undertaking and shall be taxed accordingly.

2. If a Contracting Government to the profit of a undertaking in the State of this State is included-and in accordance with it, the tax of the other Contracting Government has been taxed by this other State, and so on. profit margin, which would have been taken to the operation of the former State, the conditions which have been established between the two undertakings would have been the same as that would have been agreed between independent undertakings, shall be the same ; the second state shall make an appropriate adjustment to the tax amount calculated by the profit. The other provisions of this Agreement must take account of the other provisions of this Agreement and, if necessary, the competent authorities of the Contracting Parties shall consult each other, where necessary, consult each other.

Article 10

Exbooty

1. Exboots paid by a party belonging to a Contracting Government to a person belonging to the other Contracting Government may be subject to tax in this other state.

However, this yield may also be taxed in the Contracting Government where the company paying out the proceeds is based, and in accordance with the law of this State, but where the legal owner of the proceeds is established in the other Contracting Party ; Member States shall not, therefore, be more than :

a) 0%. of the gross amount of the yield if the rightful owner is a company which directly or indirectly owns a minimum of 50%. the capital of the undertaking which pays the proceeds and has invested more than two million euro, or similar in Danish or Georgian currency, in the capital of the undertaking which pays the proceeds ;

b) 0%. for the gross amount of the proceeds where the legal owner is the other Contracting Government or of the central bank of the State or of any public authority or other public body (including a financial institution) owned or controlled by : Government of this other State ;

c) 5%. of the gross amount of the yield if the rightful owner is a company which, directly or indirectly, owns at least 10%. the capital of the undertaking which pays the profits and has invested more than 100 000 Euro, or similar in Danish or Georgian currency, in the capital of the undertaking which pays the proceeds ;

d) 10%. of the gross amount of the yield in all other cases.

The competent authorities of the Contracting Parties shall set out by mutual agreement the detailed rules for the implementation of these restrictions.

This paragraph shall not affect access to taxing the company of profits from which the yields are paid.

3. The term "yield" as used in this Article means the income of shares, memories, units or other non-debt entitlements, and which gives the right to share in profit, as well as the income of other companies ' rights, which : shall be subject to the same fiscal treatment as the income of shares in accordance with the law of the State in which the company that carries out the encoding is based.

4. The provisions of paragraphs 1 and 2 of this Article shall not apply where the legitimate owner of the proceeds belonging to a Contracting Government operates in the other Contracting Government where the paying company is offered by the Contracting Party, the resident, through a place of permanent operating premises, or operating a free trade through a place situated, and the holding which is based on the payment of the proceeds, has a direct connection with such a fixed operation or fixed place. In this case, the provisions of Articles 7 and 14 respectively shall apply.

5. If a company belonging to a Contracting Government acquires profits or income from the other Contracting Government, then the other Member State may not impose any tax on the benefits provided by the company, unless the proceeds are paid ; a person resident in this other State, or unless the shareholding which is based on the payment of the proceeds, has a direct connection with a fixed farm operating in this other State, or to the company of the company, or non-unloaded profits on the company's non-defledable profits, even though it is : derive profit or not, wholly or partially, of profit or income derived from that other state.

Article 11

Interesters

1. Interest who originate from a Contracting Government and shall be paid to a person resident in the other Contracting Government may, if the person concerned is the rightful owner of the interest, be taxed only in this other state.

2. The term "interest" means in this Article income of debt claims of any kind, whether they are protected by the immovable property or not, and whether they contain a right to a proportion in the debtor's profit or not, and in particular the income of : State debts and the income of debt securities or depreciation, including agiobelation and gains associated with such debt certificates, bonds or depreciation.

The provisions of paragraph 1 of paragraph 1 of this Article shall not apply where the legal owner of the interest belongs in a Contracting Government, operates in the other Contracting Government from which interest is derived from the interests of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interest of the interests of the Member States, in the case of a fixed operating site or engaged in the free trade of this other state from one place situated, and the debt which is due to the interest paid shall be directly related to such a fixed operating location or location. In such cases, the provisions of Article 7 or Article 14 of this Agreement shall apply.

4. If a special connection between the person who pays interest and the rightful owner or between them and a third person has resulted in interest rates in relation to the debt debt in respect of which they are paid exceeds the amount which would be The provisions of this Article shall apply only to the latter amount, as agreed between the paying and the rightful owner, shall apply only to the latter amount. In this case the excess amount shall be subject to tax in accordance with the law of each Contracting Government, taking into account the other provisions of this Agreement.

Article 12

Royalties

1. Royalties resulting from a Contracting Government and whose rightful owner is established in the other Contracting Government may only be taxed in this other state.

2. The term "royalties" means in this Article payments of any kind received as payment for the use, or the right to use, any copyright to a literary, artistic or scientific work, including feature films, any such concept ; patent, trade mark, pattern or model, drawing, secret formula or method of manufacture, or for information on industrial, commercial or scientific experience.

The provisions of paragraph 1 of paragraph 1 of this Article shall not apply where the legal owner of the royalty amount belongs to a Contracting Government, operates in the other Contracting Government, from which the royalty of the royalty is derived ; a place of permanent farm operating or practi-free in that other State from a place of permanent location, and the right or property of the assets of the royalties situated directly related to such a fixed operating site ; or a permanent place. In such cases, the provisions of Article 7 or Article 14 of this Agreement shall apply.

4. If a special connection between the person who pays royalties and the rightful owner or between them and a third person has caused the amount of the royalty to be seen in relation to the use, privilege or information, for which it has been paid ; exceeds the amount which would have been agreed between the paying and the rightful owner, provided that such a relationship had not been available, the provisions of this Article shall apply only to the latter amount. In this case the excess amount shall be subject to tax in accordance with the law of each Contracting Government, taking into account the other provisions of this Agreement.

ARTICLE 13

Capital gains

1. Profit, as a person belonging to a Contracting Government, the transferee of the immovable property as referred to in Article 6, which is situated in the other Contracting Government, may be subject to tax in this other state.

2. Proceeding by Disposal of Pipe Property, which is part of the business asset in a fixed operating site, in a Contracting Government, in the other Contracting Government, or by disposable property belonging to a fixed location, as a resident of a Contracting Government, shall be made available for the exercise of free trade in the other Contracting Government, including the profit of the disposal of such a fixed operating location (separately or in conjunction with the entire undertaking) ; in this other state, it may be taxed in this other state.

3. Proceeding to be acquired by an undertaking in a Contracting Government by dispositing of ships and aeroplanes used in international traffic, or by any movable property associated with the operation of such ships or aircraft, can only be taxed in this State.

4. Proceeding to the disposal of all other assets other than those referred to in paragraphs 1, 2 and 3 of this Article may be taxed only in the Contracting Party in which the disposable person is resident.

ARTICLE 14

Free trade

1. income by free trade or by other work of the independent nature of a person resident in a Contracting Government may only be taxed in this state unless he has a permanent place for him at his disposal ; in the other Contracting Government for the purposes of the pursuit of his activities. If he has such a fixed location, the income may be taxed in the other state, but only to the extent that it can be executed to this permanent location.

2. The term ' free trade ` shall include, in particular, self-employed scientific, literary and artistic and educational and educational and self-employed, as a physician, a lawyer, an architect, an architect, a dentist and an accountant.

Article 15

Personal work in employment relations

Subject to the provisions of Articles 16, 18 and 19 of this Agreement, other charges may be paid, salary and other similar charges acquired by a person resident in a Contracting Government for personal work, only taxed in this State, unless the work has been carried out in the other Contracting Government. If the work has been carried out there, it may be taxed in this other state.

Notwithstanding the provisions of paragraph 1 of this Article, salaries acquired by a person resident in a Contracting Government for personal work carried out in the other Contracting Government shall be taxed only in the first state if :

a) the consignee resides in one or more periods which together does not exceed 183 days in a 12-month period commensurate or ends in that fiscal year, and

b) the remuneration shall be paid by or for an employer belonging to the former state, and

c) the remuneration is not borne by a fixed operating facility in the other Member State.

Notwithstanding the previous provisions of this Article, payment for personal work carried out on board a ship or aircraft used in international traffic of an undertaking in a Contracting Government shall be subject to taxation in the State.

Article 16

Constyliorar management

Administrative orars and other similar charges obtained by a person resident in a Contracting Government, in his capacity as a member of a company belonging to the other Contracting Government, may be taxed in this Second state.

Article 17

Artists and sportsmen

Notwithstanding the provisions of Articles 7, 14 and 15 of this Agreement, income acquired by a person resident in a Contracting Government as performers such as theatre, film, radio or television shows, or musician or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical or as a musical sportsmen shall be taxed in the other Contracting Government by way of personal life as such in the other Contracting Government.

2. If the income of personal business practised by performers or sportsmen does not belong to the artist or the sportsman himself, but a different person, this income may, notwithstanding the provisions of Articles 7, 14 and 15 of this, Agreement is taxed in the Contracting Government where the activity of the artist or the sportsmen or sportsmen is exercised.

3. The provisions of paragraphs 1 and 2 of this Article shall not apply to income acquired by an establishment in a Contracting Government of artists or sportsmen or sportsmen whose visit to this State is financed by public funds ; the one or both Contracting Governments or police-administrative subdepartments or local authorities. In such cases, the income can only be taxed in the Contracting Government where the artist or the sportsman of the sportsman is based.

Article 18

Pensions, social services and similar payments

1. Payments as a natural person resident in a Contracting Government shall receive, in accordance with the social security law of the other Contracting Government or by any other scheme from the funds provided for by this other State or of any other Member State, the relevant political subsection or local authority may be taxed in this other state.

2. Without prejudice to paragraph 1 of this Article and Article 19, paragraph 2 of this Agreement, other, pensions and other similar charges may be obtained from a Contracting Government and paid to a person resident in the other ; Contracting Governments, whether they are to be used in the past or not, are subject to taxation only in this other state. However, pensions and other similar charges may be taxed in the first Contracting Government if :

a) contributions paid by the beneficiary to the pension scheme were deduced in the recipient ' s taxable income in the former Contracting Government under the law of this State ; or

b) contributions paid by an employer were not a taxable income for the beneficiary of the former State in accordance with the law of this State.

3. Pensions must be considered to be derived from a Contracting Government if they are paid out by a pension fund or other similar institution which provides pension schemes to which natural persons can join in order to secure pensions ; when such a pension fund or other equivalent institution has been established, tax-recognised and controlled in accordance with the law of this State.

Article 19

Publicity

3. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, salaries and other similar charges, and on pensions paid for the performance of the business operations operated by a Contracting Government, or of a pension ; corresponding to the police-administrative subsection or local authority.

Article 20

Professors, teachers and scientific scientists

1. A professor, teacher or scientific researcher, who for a period not exceeding six months, visits a Contracting Government to teach or drive research at a university or other similar institution in this state, and as soon as this visit was established in the other Contracting Government, the latter shall not be taxed in the first State of remuneration for such training or research, provided that such remuneration is taxed in the other Contracting Government. This paragraph shall apply only for a period not exceeding six months from the date of the person ' s first visit to a Contracting Government with such a purpose, and shall not apply to persons who are nationals of this State.

The provisions of this Article shall apply only to the income of research, when the person performs research into the public interest and not primarily in favour of private interests.

Article 21

Students

Amount, as a student or apprentice, which is, or immediately before visiting a Contracting Government, was in the other Contracting Government and which resides in the first-mentioned state exclusively in study or training purposes ; in the case of sub-class or training, the recipient shall not be taxed in this state, provided that such amounts derive from sources outside that state.

Article 22

Other income

1. Income, acquired by a person resident in a Contracting Government which has not been processed in the preceding articles of this Agreement, may, irrespective of whence they derive, only be taxed in this State.

2. The provisions of paragraph 1 of this Article shall not apply to income, with the exception of the income of real estate as defined in Article 6, paragraph 2 of this Agreement, if the recipient of such income is provided in a Contracting Government, business activities in the other Contracting Government through a place of establishment or operating freely from a place of establishment, and the right or property of the income of the paid income, has directly, connectivity with such a fixed operating location or location. In such cases, the provisions of Article 7 or Article 14 of this Agreement shall apply.

The provisions of this Article shall not apply to taxes on benefits that natural persons receive from gambling and lotteries.

Article 23

Repeal of double taxation

Double taxation must be avoided in the following manner :

1. In Denmark :

Where a person belonging to Denmark acquires income which, according to the provisions of this Agreement, may be subject to tax in Georgia, unless the provisions of point (c) of this paragraph result in other-reduce the tax of the person concerned ; on the income of an amount equal to the income tax paid in Georgia.

However, this deduction shall not exceed that part of the income tax calculated before the deduction may be attributed to the income tax which may be taxed in Georgia.

If a person belonging to Denmark acquires income which, according to the provisions of this agreement, only subject to taxation in Georgia, Denmark may include this income in the taxable amount, but must reduce income tax with the part which may be is carried out to the income derived from Georgia.

2. In Georgia :

a) When a person resident in Georgia acquires income which, according to the provisions of this Agreement, may be taxed in Denmark, Georgia must reduce the income of the person concerned on the income of an amount equal to the income tax which is paid in Denmark. However, this deduction shall not exceed that part of the income tax calculated before the deduction may be attributed to the income tax which may be taxed in Denmark.

b) When a person resident in Georgia acquires income which, according to the provisions of this agreement, exempt from taxation in Georgia, Georgia must nevertheless take the exempted income in view of the calculation of the tax on the person ' s personal income ; other income.

ARTICLE 24

Non-discrimination

1. Member State nationals of a Contracting Government shall not be subject to any tax or related claims in the other Contracting Government in the other Contracting Government, which are different or more cumbersome than the taxation and related requirements of nationals of this Directive ; the second state under the same conditions, in particular as regards its head office, is or may be subject to submission. Notwithstanding the provisions of Article 1 of this Agreement, this provision shall also apply to persons not belonging to one of or both of the Contracting Parties.

2. Stateless persons belonging to a Contracting Government shall not be subject to any tax or related claims in any of the Contracting States which are different or more cumbersome than the taxation and related charges ; requirements of nationals of the State concerned under the same conditions, in particular as regards their registered office, or may be subject to notification.

3. The taxation of a fixed farm operating in a Contracting Government of the other Contracting Government may not be less advantageous in this other state than the taxation of undertakings in this other state by the practice of the same establishment. This provision should not be interpreted as binding a Contracting Government to allow persons belonging to the other Contracting Government, the personal tax benefits, relaxes and reductions, as the result of : a conjugal position or a grievout duty to the families of people who are indigenous to their own territory.

4. Unless the provisions of Article 9, paragraph 1, Article 11, paragraph 4, or Article 12, paragraph 4 of this Agreement shall apply, interest, royalties and other payments made by an undertaking in a Contracting Government to a person who, where the taxable profit of such a undertaking is situated in the other Contracting Government, subject to the same conditions, under the same conditions, as if they had been paid to a person resident in the former ; State.

5. Undertaking in a Contracting Government whose capital is owned or controlled directly or indirectly, by one or more persons belonging to the other Contracting Government, not in the first-mentioned state should not be subject to the following : any taxation or related requirements, which are different or more cumbersome than the taxation and related requirements of other similar undertakings in the former or may be subject to the conditions of the latter.

Article 6, notwithstanding the provisions of Article 2 of this Agreement, the provisions of this Article shall apply to taxes of any kind and description.

ARTICLE 25

Procedure for the conclusion of reciprocal agreements

1. If a person considers that the measures taken by one or both of the Contracting Governments for him may or may not comply with the provisions of this Agreement, he may, irrespective of the legal remedies available to him, may or may not, may be required by the internal legislation of these States, subject to the competent authority of the Contracting Government where he is a resident or, where his case is subject to Article 24, paragraph 1, for the competent authority of the competent authority of the Contracting Party concerned, Contracting Government, where he is a national. The matter must be brought before three years from the date on which he is given the first notification of the measure resulting from a tax that is not in accordance with the provisions of this Agreement.

2. The competent authority must, where the notice appears to be justified, and if it is not itself able to reach a reasonable solution, the matter may seek to resolve the matter by mutual agreement with the competent authority of the other Contracting Government for the purpose of the latter ; to avoid taxation that is not in conformity with this Agreement. Any contract concluded shall be implemented without regard to the time limits laid down in the internal legislation of the Contracting Parties.

3. The competent authorities of the Contracting Parties shall seek mutual agreement to resolve any difficulties or doubts which may arise in the interpretation or application of this Agreement. They can also negotiate the avoidance of double taxation in cases not covered by the agreement.

4. The competent authorities of the Contracting Parties may enter directly to each other, including through a joint commissions composed of them themselves or their representatives, with a view to the conclusion of an agreement in accordance with them ; previous paragraphs.

Article 26

Exchange of information

1. The competent authorities of the Contracting Parties shall exchange such information which is likely to be relevant to the implementation of the provisions of this Agreement or to the administration or enforcement of the Contracting Governments ; internal laws relating to taxation of any kind or designation imposed on behalf of the Contracting Governments or their police-administrative subdepartments or local authorities, provided that such taxation does not contradict the Agreement. The exchange of information shall not be limited by Articles 1 and 2 of this Agreement.

2. Any information received by a Contracting Government after paragraph 1 of this Article shall be treated as secret in the same way as information provided under this State ' s internal law and may be granted only to persons or persons ; authorities (including courts and administrative authorities) engaged in the equation, collection, recovery, enforcement or prosecution in respect of, or complaints, in relation to the taxes referred to in paragraph 1 of this Regulation ; Article, or at the time of supervisory functions. Such persons or authorities may use this information only for the purposes mentioned. You may communicate information to the public or to court rulings.

The provisions of paragraph 1 of paragraph 1 and 2 of this Article may in no case be interpreted as to the obligation of a Contracting Government to :

a) to carry out administrative areas which are contrary to the laws and practices of this or other Contracting Government ;

b) to provide information which cannot be obtained under the legislation or general management practices of this or the other Contracting Government of the other ;

4. If a Contracting Government asks for information in accordance with this Article, the other Contracting Government shall take steps to obtain the information requested, even though this other State may not have need for them ; information for its own tax purposes. The obligation laid down in the preceding sentence shall be subject to the limitations of paragraph 3 of this Article, but in no case allows a Contracting Government not to provide information solely on the grounds that : this State itself does not have any tax interest in such information.

In no case may the provisions of paragraph 3 of this Article be interpreted as making it possible for a Contracting Government to refuse information simply because the information is to be obtained from a bank, another financial institution ; either a representative or a person acting as authorised or as a guaran or because the information relates to ownership of a person.

ARTICLE 27

Members of diplomatic representations and consular posts

Nothing in this Agreement shall affect the tax benefits granted by members of diplomatic representations or consular offices in accordance with the general rules or special agreements of the international law.

Article 28

Protocol and amendments

1. The associated protocol shall form an integral part of this Agreement.

2. Amendments and additions to this Agreement may be carried out in the form of protocols, which shall constitute an integral part of this Agreement. Such protocols shall enter into force on the same conditions as set out in accordance with Article 29 of this Agreement.

ARTICLE 29

Entry into force

The governments of the Contracting Governments of the Contracting Governments must, by diplomatic means, give each other a notification that the conditions laid down in their legislation on the entry into force of this Agreement are fulfilled.

2. This Agreement shall enter into force on the first day of the third month following the month in which the last notification by the Contracting Governments of the implementation of the legal procedures necessary for the entry into force of the Agreement is received. This agreement shall take effect in respect of taxes for any financial year which begins on 1. January or later in the calendar year following the entry into force of the year in which the Agreement enters into force.

Article 30

Termination

This Agreement shall remain in force until it is terminated by a Contracting Government. Each Contracting Party may terminate the Agreement after the end of a period of five years from the date of entry into force of the Agreement by means of diplomatic means of giving the other Contracting Government a written notification of termination of at least six months before the end of the expiry date ; of a calendar year. In this case, this agreement shall cease to have an effect on taxes for any financial year beginning on 1. January or later in the calendar year following the year in which the notification of termination has been given.

In the case of the undersigned, duly authorised, they shall have signed this Agreement.

Done at two copies in Copenhagen on 10. October 2007 in English.

For the Government of the Kingdom of Denmark

Kristian Jensen

For the government of Georgia

Gela Bezhuashvili

PROTOCOL

to

APPOINTMENT

MEDITO

THE GOVERNMENT OF THE KINGDOM OF DENMARK AND

GOVERNMENT OF GEORGIA

FOR THE AVOIDANCE OF DOUBLE TAXATION

AND THE PREVENTION OF TAX EVASION

IN THE CASE OF INCOME TAXES,

In the signing of the Agreement between the Government of the Kingdom of Denmark and the Government of Georgia to avoid double taxation and prevent tax evasion as far as income taxes are concerned, they agree that the following provisions shall be agreed : constitute an integral part of the Agreement :

1. Interpretation of the Agreement

It is a common understanding that the provisions of the Agreement, drawn up in accordance with the corresponding provisions of the OECD model for double taxation charges in respect of taxes on income and wealth, should be attached to it in general terms ; importance that is expressed in the OECD's comments on the model. This common understanding shall not apply in respect of :

a) the reservations or observations of the Contracting Parties in relation to the OECD model or the comments thereon,

b) deviant interpretation which the competent authorities may agree upon after the agreement has entered into force.

The OECD comments-which they had to change from time to time-represent an interpretative contribution as referred to in the Vienna Convention of 23. May 1969 on Treaty law.

2. Regarding Article 2, paragraph 3 (b)

It is noted that, in accordance with the provisions of Georgian tax law, a wealth tax is to be paid in Georgia.

3. Regarding Article 3, paragraph 1 (e)

It is a common understanding that the expression 'company' should be interpreted in such a way that the expression means any legal person or entity which is treated as a legal person in fiscal terms as a legal person, when such a legal person or other entity is practised, financial business.

4. Regarding Article 4

It is common understanding that a legal person established in Denmark under the law of Denmark, with the aim of making pensions and other similar services available to natural persons, and which is generally exempt from taxation in Denmark shall be deemed to be indigenous in Denmark by applying this Agreement.

5. Regarding Article 8

It is a common understanding that the profits of ships and aeroplanes in international traffic comprise profit by boning on bareto terms of ships or aeroplanes, or profits by using or renting containers (including trailers, barge and similar equipment for the carriage of containers), where such profits are affining to the other profit by the operation of ships or aircraft in international traffic.

6. Regarding Articles 8 and 13

It is a common understanding on the profits and capital gains made by the Danish, Norwegian and Swedish air consortium Scandinavian Airlines System (SAS) that the provisions of Article 8 and Article 13 shall apply only to the part of the profit or capital gains corresponding to the share of the consortium owned by the Danish partner.

In the case of the undersigned, duly authorised, the signatory shall have signed this Protocol.

Done at two copies in Copenhagen on 10. October 2007 in English.

For the Government of the Kingdom of Denmark

Kristian Jensen

For the government of Georgia

Gela Bezhuashvili