AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF BELARUS AND GOVERNMENT OF THE LAO PEOPLE'S DEMOCRATIC REPUBLIC

of July 1, 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 Lao People's Democratic Republic,

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 and also capital gain taxes (property) are considered as taxes on the income.

3. The existing taxes to which this agreement extends are, in particular:

a) in the Republic of Belarus:

(i) tax on the income;

(ii) income tax; and

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

b) in the Lao People's Democratic Republic:

(i) income tax (income) of the companies and organizations; and

(ii) the income tax from physical persons (further - "the Laotian 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 specified in Item 3 of this Article. 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 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;

b) the term "Laos" means the territory of the Lao People's Democratic Republic; when using in geographical sense - all its national territory, including territorial waters and any territory outside territorial waters concerning which the Lao People's Democratic Republic according to the national legal system and international law can perform the sovereign rights on investigation and development of natural resources of bed of the river, its subsoil and the covering resources;

c) the terms "one Contracting State" and "other Contracting State" mean Belarus or Laos depending on context;

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

e) the term "company" means any legal entity or any organization which for the purposes of the taxation is considered as the separate organization;

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 "permanent base" includes the permanent place, such as office or office through which independent activities of the physical person rendering independent personal services are fully or partially performed;

h) the term "international delivery" means any transportation sea either the aircraft or road transport operated by the company which place of the actual management is located in one Contracting State, except as specified, when sea either the aircraft or road transport is operated only between the Items located in other Contracting State;

i) the term "national person" means:

(i) any physical person having nationality of the Contracting State;

(ii) any legal entity, partnership or association which received the status by the legislation existing in the Contracting State;

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

k) the term means "competent authority":

(i) in Belarus - the Ministry of Taxes and Tax Collection of the Republic of Belarus or his plenipotentiary;

(ii) in Laos - the Minister of Finance or his plenipotentiary.

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