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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.


General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) the terms "a Contracting State" and "other Contracting State" mean Belarus or Syria, as the context requires;
  • (b) the term "Belarus" means the territory over which the Republic of Belarus exercises under the laws of Belarus and in accordance with international law sovereign rights and jurisdiction;
  • (c) the term "Syria" means the Syrian Arab Republic in its geographical sense, which means the territory of the Syrian Arab Republic including its territorial sea, the continental reef, the subsoil, the air space above it and all other areas outside the Syrian territorial sea within which; in accordance with international law and its national legislation, Syria exercises sovereign rights for the purpose of extracting and exploiting the natural, vital and mining resources and all other rights in the water, on land and under the seabed;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State;
  • (f) the term "company" means any legal person or any entity which is treated as a separate entity, for tax purposes;
  • (g) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (h) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (i) the term "fixed base" means a fixed place such as an office or room, through which the activity of an individual performing independent personal services is wholly or partly carried on;
  • (j) the term "competent authority" means:
    • (i) in the case of Belarus, the State Tax Committee of the Republic of Belarus or its authorized representative;
    • (ii) in the case of Syria, the Minister of Finance or his authorized representative.

(2) As regards the application of the Agreement by a Contracting State, any term not defined therein shall have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies, which meaning shall prevail over the meaning provided for such term in other branches of law of that State.