Treaty between Saudi Arabia and Belarus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains

Signed on 20 July 2009, the tax treaty between Saudi Arabia and Belarus applies starting from 2011.

The main provisions of the treaty are as follows:

Permanent establishment

The term ‘permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

The term ‘permanent establishment' also includes:

• a building site, a construction, assembly or installation project or any supervisory activity in connection with such site or project, but only where such site, project or activity continue for a period of more than 6 months,

• The furnishing of services including consultancy services by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or connected project) within the country for a period or periods aggregating more than 6 months within any 12 month period.

Dividends