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of July 19, 2000

About avoidance of double taxation and prevention of tax avoidance on the income and property

(Protocol as amended of 19.05.2016)

The government of the Republic of Belarus and the Government of the Republic of Armenia, being guided by the aspiration to develop and strengthen economic, scientific, technical and cultural cooperation between both Contracting States and for the purpose of elimination of double taxation on the income and property, prevention of tax avoidance and non-admission of tax discrimination, decided to sign this agreement and 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 taxes on the income and property, the collectable Contracting State or regional authorities, irrespective of method of their collection.

2. All taxes levied from the total amount of the income on the total amount of property or from their separate elements, including taxes on the income from property acquisition, taxes on the total amount of the salary paid by the companies and also the property increment value duties are considered as taxes on the income and property.

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

a) in the Republic of Armenia:

(i) income tax of legal entities;

(ii) the income tax from physical persons;

(iii) property tax;

b) in the Republic of Belarus:

(i) tax on the income of the foreign organizations;

(ii) income tax;

(iii) the income tax from physical persons;

(iv) real estate tax.

4. This agreement is applied also to all identical or in essence to similar taxes which are levied in addition to the existing taxes, or instead of them, after signature date of this agreement. Competent authorities of Contracting States timely notify each other on the essential changes made to their corresponding tax legislations.

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" mean, depending on context, Armenia or Belarus;

b) the term "Armenia" means the Republic of Armenia and when it is used in geographical sense, means the territory concerning which the Republic of Armenia performs the sovereign rights and jurisdiction according to rules of international law and the domestic legislation;

c) the term "Belarus" means the Republic of Belarus and when using in geographical sense means the territory which is under sovereignty of the Republic of Belarus and which according to the legislation of Belarus and international law is under jurisdiction of the Republic of Belarus;

d) the term "person" includes physical person, the company and any other consolidation of persons;

e) the term "company" means any legal entity or any other education which for the purposes of the taxation is considered as the legal entity;

f) the terms "company of one Contracting State" and "company of other Contracting State" mean respectively, the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

g) the term "international delivery" means any transportation sea or the aircraft, automobile or the rail vehicle operated by resident of one Contracting State, except as specified, when such transportation is performed only between the Items located in other Contracting State;

h) the term means "competent authority":

(i) in relation to Armenia – the Ministry of Finance or Committee of state revenues under the Government of the Republic of Armenia or their plenipotentiaries;

(ii) in relation to Belarus – the Ministry of Taxes and Tax Collection or its plenipotentiary;

i) the term "national person" (citizen)" means:

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association which received the status as such based on the current legislation of the Contracting State;

j) the term "company" is applied to implementation by person of any business activity;

k) the term "business activity" includes rendering professional services and implementation of other business activity of independent nature;


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