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LAW OF THE REPUBLIC OF BELARUS

of November 29, 2013 No. 76-Z

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

Accepted by the House of Representatives on October 24, 2013

Approved by Council of the Republic on November 15, 2013

Ratify the Agreement between the Government of the Republic of Belarus and the Government of the Republic of Singapore on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income signed in Singapore on March 22, 2013.

President of the Republic of Belarus

A. Lukashenko

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

of March 22, 2013

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

Government of the Republic of Belarus and Government of the Republic of Singapore,

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

agreed as follows:

Article 1. Persons to whom this agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States.

Article 2. Taxes to which this agreement extends

1. This agreement is applied to the taxes on the income 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 or from income elements including taxes on the income from alienation of personal or real estate are considered as taxes on the income.

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

a) in Belarus:

(i) tax on the income;

(ii) income tax;

(iii) the income tax from physical persons

(further - "the Belarusian tax");

b) in Singapore:

tax on the income

(further - "the Singapore tax").

4. This agreement extends also to any identical or in essence the similar taxes levied after signature date of this agreement in amendment or instead of the existing taxes. 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:

a) the terms "one Contracting State" and "other Contracting State" mean Belarus or Singapore depending on context;

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

c) the term "Singapore" means the Republic of Singapore and when using in geographical sense includes its territory, internal waters and the territorial sea, and also any area outside the territorial sea of Singapore which was or can be determined further according to the national legal system or international law as the area in the territory of which Singapore can perform the sovereign rights or jurisdiction concerning sea space, its bottom, subsoil and natural resources;

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

e) "company" means the term:

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

(ii) in Singapore - any corporation or any organization which for the purposes of the taxation is considered as corporation;

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 operated by the company of the Contracting State, except as specified, when sea or the aircraft is operated only between the Items located in other Contracting State;

h) the term "national person" concerning the Contracting State means:

i) any physical person having nationality of this Contracting State; and

ii) any legal entity, partnership or association which received the status by the legislation existing in this Contracting State;

i) the term means "competent authority":

(i) in Belarus - the Ministry of Taxes and Tax Collection of the Republic of Belarus or his plenipotentiary;

(ii) in Singapore - the Minister of Finance or his plenipotentiary;

j) the term "legal body" means the body created according to the legislation and performing only non-commercial functions which would otherwise be performed by the Government of the Contracting State.

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