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LAW OF THE REPUBLIC OF BELARUS

of January 4, 2014 No. 114-Z

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

Accepted by the House of Representatives on December 16, 2013

Approved by Council of the Republic on December 19, 2013

Ratify the Agreement between the Government of the Republic of Belarus and the Government of the Democratic Socialist Republic of Sri Lanka on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income signed in Minsk on August 26, 2013.

President of the Republic of Belarus

A. Lukashenko

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF THE DEMOCRATIC SOCIALIST REPUBLIC OF SRI LANKA

of August 26, 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 Democratic Socialist Republic of Sri Lanka,

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, taxes on the total amount of 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 Belarus:

(i) tax on the income;

(ii) income tax;

(iii) the income tax from physical persons (further - "the Belarusian tax");

b) in Sri Lanka:

tax on the income, including the tax on the income based on turnover of the companies which signed agreements with Committee on investments (further - "Lankan 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 Sri Lanka 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 "Sri Lanka" means the territory of the Democratic Socialist Republic of Sri Lanka according to determination under the Constitution of the Democratic Socialist Republic of Sri Lanka and includes its overland territory, internal waters and the territorial sea, airspace over them, and also exclusive economic zone and the continental shelf where the Democratic Socialist Republic of Sri Lanka performs or can perform further the sovereign rights and jurisdiction according to rules of international law and its national legal system;

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

e) "company" means the term:

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

(ii) in case of Sri Lanka - 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 which place of the actual management is located in one Contracting State, except as specified, when such sea or the aircraft is operated only between the Items located in other Contracting State;

h) the term "place of the actual management" means the place in which the actual control and control over the company is exercised and (or) in which top-level decisions on the important issues essential to company management are made;

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

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