SolvedDT3301A | Double Taxation Relief Manual: Belarus: Treaty Summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Belarus are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 5% | 10 |
| Dividends on direct investments | 5% | 10 |
| Conditions for lower rate on dividends on direct investments | Not applicable – 5% rate applies to all dividends other than property income dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 5% (Note 1) | 11 |
| Royalties | 5% (Note 2) | 12 |
| Government pensions | Taxable by the paying state, except where the individual is a national and resident of the other state. | 18 |
| Other pensions/annuities | Taxable in state of residence, except lump sums taxable in the state of source. | 17 |
| Arbitration | No (Note 3) | 24 |
Note 1: Interest paid in the following circumstances is taxable only in the state of residence of the beneficial owner of the interest: interest paid to;
the Government;
the Bank of England;
a UK statutory body;
a bank;
any institution wholly or mainly owned by the Government of the UK as may be agreed from time to time by the competent authorities.
Note 2: The definition of royalties includes payments for equipment leasing. See notes page for further details.
Note 3: In accordance with paragraph 7 of the Protocol to the agreement, the arbitration provision at paragraph 5 of Article 24 will apply only when the UK and Belarus have agreed a date for its commencement through an exchange of diplomatic notes.