DT3301B - Double Taxation Relief Manual: Guidance by country: Belarus: Notes
Article 12
The definition of royalties in Article 12 includes payments for equipment leasing (“payments for the use of, or the right to use, industrial, commercial or scientific equipment”). 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:
- on or after 26 September 2017; or
- before 26 September 2017 where the equipment provided under the contract was delivered on or after 26 September 2017.