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Protocol to Tax Treaty between Armenia and Belarus has Entered into Force

The protocol to the 2000 income tax treaty between Armenia and Belarus entered into force on 26 December 2016. The protocol is the first to amend the treaty, and includes:

  • Amendments to Article 2 (Taxes Covered) with respect to Armenian taxes;
  • Amendments to Article 3 (General Definitions) with respect to the definition of the terms competent authority, enterprise, entrepreneurial activity, professional services, and place of effective management;
  • Amendments to Article 4 (Resident) to provide reference to place of effective management in determining residence;
  • Amendments to Article 6 (Income from Immovable Property) regarding the definition of the term immovable property;
  • Amendments to Article 12 (Royalties) to add payments for the use of, or the right to use, computer programs within the scope of royalties;
  • Amendments to Article 13 (Capital Gains) to provide for the taxation of gains by a Contracting State that are derived from the alienation of shares or other interests in a company deriving more than 50% of their value from immovable property situated in that State; and
  • The replacement of Article 26 (Exchange of Information) to bring it line with the OECD standard for information exchange.

The protocol applies from 1 January 2017.

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