background image
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.

ARTICLE 2

Taxes Covered

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

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of property, taxes on the total amounts of wages or salaries paid by enterprises as well as taxes on property appreciation.

(3) The existing taxes to which the Agreement shall apply are in particular:

  • (a) in the case of the Republic of Belarus:
    • (1) the tax on income and profits of enterprises, associations, organizations;
    • (2) the income tax on individuals;
    • (3) the tax on immovable property;
  • (hereinafter referred to as "the Belarusian tax");
  • (b) in the case of the Syrian Arab Republic:
    • (1) the income tax on commercial, industrial and non-commercial profits;
    • (2) the income tax on salaries and wages:
    • (3) the income tax on non-residents;
    • (4) the income tax on revenue from property;
    • (5) surcharges imposed as percentages of the above taxes or in any other form or rate
  • (hereinafter referred to as "the Syrian tax").

(4) The Agreement shall apply also to any identical or similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of substantial changes which have been made in their respective taxation laws.