DT3301B - Double Taxation Relief Manual: Guidance by country: Belarus: Notes

Article 12

The definition of royalties in Article 12 includes payments for equipment leasing (鈥減ayments for the use of, or the right to use, industrial, commercial or scientific equipment鈥�). However, by virtue of paragraph 5 of the Protocol to the agreement, the taxing right of Belarus in respect of such payments is limited to:

a) a measure of net profit (defined as the difference between the gross receipt and expenses related to it in respect of equipment insurance, bank interest and reimbursement of equipment value); and

b) payments made under contacts concluded:

  1. on or after 26 September 2017; or
  2. before 26 September 2017 where the equipment provided under the contract was delivered on or after 26 September 2017.