The protocol to the Agreement between the Government of the Republic of Belarus and the Government of the Russian Federation about avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and property of April 21, 1995
of January 24, 2006
Government of the Republic of Belarus and Government of the Russian Federation,
being guided by desire to sign the Protocol to the Agreement between the Government of the Republic of Belarus and the Government of the Russian Federation about avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and property of April 21, 1995 (further - the Agreement),
agreed about the following provisions which are integral part of the Agreement:
1. Taking into account provisions of article 14 of the Agreement the reward earned by physical person with the permanent residence in one Contracting State (the citizen of the Republic of Belarus or the Russian Federation) concerning the work for hire which is carried out in other Contracting State during the stay period in this other Contracting State constituting at least 183 days in calendar year or is continuous within 183 days which began in prior calendar year and expiring current calendar year can be assessed with tax in this other Contracting State according to the procedure and at the rates provided concerning persons with the permanent residence in this Contracting State.
2. The tax regime set in Item 1 of this Article is applied from start date of work for hire in other Contracting State which duration according to the employment contract constitutes at least 183 days.
3. If person in one Contracting State signs several employment contracts in other Contracting State, duration of work on which separately constitutes less than 183 days in calendar year, with the permanent residence, the tax regime set in Item 1 of this Article is applied from start date of work on the first employment contract according to which work duration in this other State, taking into account work on the previous employment contracts, will constitute at least 183 days.
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