The protocol to the Convention between the Government of the Republic of Belarus and the Government of Turkmenistan on avoidance of double taxation concerning taxes on the income and the capital (property) of May 17, 2002

of November 14, 2012

The government of the Republic of Belarus and the Government of Turkmenistan which further are referred to as with the Parties

wishing to sign the Protocol to the Convention between the Government of the Republic of Belarus and the Government of Turkmenistan on avoidance of double taxation concerning taxes on the income and the capital (property) of May 17, 2002 (dalee-Konvention),

agreed that the following provisions constitute integral part of the Convention:

Article 1

The works (services) performed (rendered) by the company of one Contracting State, connected with the construction and (or) installation and (or) assembly on the building site, construction, mounting or assembly object located in other Contracting State, such as preproject, engineering, design, project, design and survey, proyektnokonstruktorsky, research works, services of designer's and technical service of construction, services in training or the organization of training do not fall under action of Item 3 of article 5 of the Convention if such works (services) are performed (appear) not in the territory of this other Contracting State.

Article 2

If the company of one Contracting State realizes goods, property, intangible assets or performs other business activity in other Contracting State through the permanent mission located in this other Contracting State, then, in case of application of Items 1 and 2 of article 7 of the Convention, the profit of such permanent mission will be determined not based on the total amount of the gross income (sales proceeds and non-operating incomes) received by the company of the first Contracting State, and total amount of deductions (expenses) of this company, and proceeding from belonging to the actual activities of this permanent mission in other Contracting State of the amount of gross income (sales proceeds and non-operating incomes) and the amounts of deductions (expenses) made including, in the first Contracting State.

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