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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or one of its local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and capital, all taxes imposed on total income, on total capital, or on elements of income or capital, including taxes on gains from the alienation of movable or immovable property as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are in particular:

  • (a) In the Federal Republic of Germany:
    • (i) Tax on income of individuals;
    • (ii) Corporation tax;
    • (iii) Capital tax; and
    • (iv) Municipal trade tax, including any surcharges levied on such taxes;
  • (hereinafter referred to as "German taxes");
  • (b) In the Republic of Belarus:
    • (i) Tax on income and profits;
    • (ii) Tax on income of individuals;
    • (iii) Tax on immovable capital; and
    • (iv) Tax on real estate;
  • (hereinafter referred to as Belarusian taxes).

(4) This Convention shall also apply to taxes of an identical or substantially similar nature that are imposed after the date of signature of this Convention in addition to, or instead of, the existing taxes. The competent authorities of the Contracting States shall, at the end of each year, notify each other of any significant changes made in their respective tax laws for the purpose of implementing the provisions of this Convention.