Common use of ELIMINATION OF DOUBLE TAXATION Clause in Contracts

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income which is taxed in Lithuania in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income which is may be taxed in Lithuania South Africa in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 paragraph 5 of Article 12, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 5 of Article 12, the Lithuanian South African tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium Belgium, from a company which is a resident of Lithuania, South Africa shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaSouth Africa, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph subparagraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also not been exempted from subjected to tax in Lithuania South Africa by reason of compensation for the said losses. 2. In the case of South Africa: a) Belgian taxes paid by residents of South Africa in respect of income taxable in Belgium, in accordance with the provisions of the Convention, shall be deducted from the taxes due according to South African fiscal law. Such deduction shall not, however, exceed that part of the South African tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. b) As regards the application of the provisions of subparagraph a), it is understood that the amount of the South African tax which is attributable to such income which has been subjected to tax in Belgium shall be: (i) where the tax on such income is computed by applying a proportional rate, the amount of the net income concerned multiplied by that rate; and (ii) where the tax on such income is computed by applying a progressive scale, an amount which bears to the net income concerned the same ratio as the total tax payable bears to the total net income which is subject to tax in accordance with South African fiscal law.

ELIMINATION OF DOUBLE TAXATION. 1. In Subject to the case provisions of Lithuaniathe laws of Japan regarding the allowance as a credit against Japanese tax of tax payable in any country other than Japan, double taxation shall be avoided as follows: where a resident of Lithuania Japan derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income Belgium which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income which is taxed in Lithuania in accordance with the provisions of this Convention, other than those the amount of paragraph 2 Belgian tax payable in respect of Article 10that income shall be allowed as a credit against the Japanese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of paragraphs 2 and 7 the Japanese tax which is appropriate to that income. (a) Where a resident of Article 11 and Belgium derives income, not being dividends, interest or royalties, which is taxed in Japan in accordance with the provisions of paragraphs 2 and 6 of Article 12this Convention, Belgium shall exempt such income from tax but mayif such resident is an individual, Belgium shall only exempt such income from tax to the extent that such income is effectively taxed in Japan. (b) Notwithstanding the provisions of subparagraph (a) and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels – beroepsinkomsten) that is exempted from tax in Belgium in accordance with that subparagraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had arisen in Belgium. Where in accordance with any provision of the Convention income derived by a resident of Belgium is exempted from tax in Belgium, Belgium may nevertheless, in calculating the amount of tax on the remaining income of that such resident, apply the rate of tax which would have been applicable if such income had not been exempted. b(c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of Japan shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where a company which is a resident of Belgium derives from a company which is a resident of Japan dividends which are not exempted in accordance with subparagraph (c), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of Japan is effectively engaged in the active conduct of a business in Japan. In such case, such dividends shall be exempted under the conditions provided for in Belgian law except those conditions that are related to the taxation of the company which is a resident of Japan or the income out of which the dividends are paid. The provisions of this subparagraph shall only apply to dividends paid out of income generated by the active conduct of a business and shall not apply to the extent that the company that is a resident of Japan has deducted, or may deduct, the dividends from its profits. For the purposes of this subparagraph, a company shall not be considered to be effectively engaged in the active conduct of a business in Japan where such company is an investment company, a financing company (other than a bank) or a treasury company or where such company holds any portfolio investment or any copyright, patent, trade xxxx, design, model, plan, secret formula or process which represents in the aggregate more than a third of its assets and such holding is not part of the active conduct of a business. (e) Where a company which is a resident of Belgium derives from a company which is a resident of Japan dividends which are included in its aggregate income for Belgian tax purposes and which are not exempted from the corporate income tax according to subparagraph (c) or (d), the Japanese tax charged on such dividends in accordance with paragraph 2 of Article 10 shall be allowed as a credit against Belgian tax relating to such dividends. The credit allowed shall not exceed that part of the Belgian tax which is proportionally relating to such dividends. (f) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Japanese tax levied charged on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d(g) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, Japan have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph subparagraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that permanent establishment to the extent that those profits have also been exempted from tax in Lithuania Japan by reason of compensation for the said deduction of such losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaGeorgia, double taxation shall be avoided as follows: where : (a) Where a resident of Lithuania Georgia derives income or owns capital which, in accordance with the provisions of this ConventionAgreement, may be taxed in Belgium, unless Georgia shall, subject to the provisions of paragraphs (b) and (c), exempt such income or capital from tax. (b) Where a more favorable treatment is provided resident of Georgia derives items of income which, in its domestic lawaccordance with the provisions of Articles 10, Lithuania 11 and 12, may be taxed in Belgium, Georgia shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in LithuaniaGeorgian tax, as computed before the deduction is given, which is attributable to such items of income derived from that other State. (c) Where in accordance with any provision of the Agreement income which derived or capital owned by a resident of Georgia is exempt from tax in that State, Georgia may be taxed nevertheless, in Belgiumcalculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 2. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income or owns elements of capital which is are taxed in Lithuania Georgia in accordance with the provisions of this ConventionAgreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 1200, Belgium Xxxxxxx shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. (b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10dividends, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11interest, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Georgian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. (c) Dividends within the meaning of paragraph 3 of Article 10Dividends, derived by a company which is a resident of Belgium from a company which is a resident of LithuaniaGeorgia, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaGeorgia, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-sub- paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Georgia by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided eliminated as follows: a) Where a resident of Belgium derives income income, not being dividends, interest or royalties, which is taxed in Lithuania China in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12Agreement, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) The exemption provided by sub-paragraph a) shall also be granted with respect to income treated as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that derives its status as such from the laws of China, where that entity has not been taxed as such by China, provided that the resident of Belgium has been taxed by China, proportionally to his participation in such entity, on the income out of which the income treated as dividends under Belgian law is paid. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of China, shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where a company which is a resident of Belgium derives from a company which is a resident of China dividends which are not exempted according to sub-paragraph c), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of China is effectively engaged in the active conduct of a business in China. In such case, such dividends are exempted under the conditions and within the limits provided for in Belgian law except those related to the fiscal regime applicable to the income out of which the dividends are paid. e) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Chinese tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. df) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaChina, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania China by reason of compensation for the said losses. 2. In China, double taxation shall be eliminated as follows: a) Where a resident of China derives income from Belgium the amount of tax on that income payable in Belgium in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China. b) Where a dividend is paid by a company which is a resident of Belgium to a company which is a resident of China and which owns not less than 20 per cent of the shares of the company paying the dividend, the credit shall take into account the Belgian tax paid by the company paying the dividend in respect of its income.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which is taxed in Lithuania the Philippines in accordance with the provisions of this ConventionAgreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 1200, Belgium Xxxxxxx shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b(i) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph (c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph paragraphs 2 or 6 of Article 12, the Lithuanian Philippine tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. (ii) Belgium shall also allow against its tax a credit with respect to dividends, interest and royalties derived by a resident of Belgium and included in the aggregate income for Belgian tax purposes of this resident, when Philippine tax may be charged on these items of income according to the provisions of the Agreement and the general law of the Philippines, but no Philippine tax is effectively levied under special and temporary measures which are designed to promote investments directly connected with development projects in the Philippines and which are agreed upon by the competent authorities of both Contracting States. Such credit shall be calculated at the rate of 10 per cent of the gross amount of the income, but shall not exceed that part of the Belgian tax, as computed before the credit is given, which is attributable to these items of income and shall only apply for the first ten years for which the Protocol amending the Agreement is effective. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuaniathe Philippines, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuaniathe Philippines, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-sub- paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania the Philippines by reason of compensation for the said losses. 2. In the Philippines, in accordance with the provisions and subject to the limitations of the laws of the Philippines, as may be amended from time to time without changing the general principles hereof, double taxation shall be avoided in the following manner: (a) In accordance with the principles of this Agreement, taxes paid or accrued under the laws of Belgium, whether directly or by deduction, in respect of income from sources within Belgium shall be allowed as a credit against Philippine tax subject to the following limitations: (i) the amount of credit in respect to the tax paid or accrued to Belgium shall not exceed the same proportion of taxes covered by the Agreement against which such credit is taken, which the taxpayer's taxable income from sources within Belgium bears to his entire taxable income for the same taxable year; and (ii) the total amount of the credit shall not exceed the same proportion of the taxes covered by theAgreement against which such credit is taken, which the taxpayer's taxable income from sources without the Philippines bears to his entire taxable income for the same taxable year. (b) In the case of a Philippine corporation owning directly or indirectly more than 50 per cent of the voting stock of a Belgian company from which it receives dividends in any taxable year, the Philippines shall also allow credit for the appropriate amount of taxes paid or accrued to Belgium by a Belgian company paying such dividends with respect to such profits out of which such dividends are paid. The deduction shall not, however, exceed that part of the Philippine income tax, as computed before the deduction is given, which is appropriate to the income which may be taxed in Belgium.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaUganda, double taxation shall be avoided eliminated as followsfollows : where Where a resident of Lithuania Uganda derives income which, in accordance with the provisions of this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania Uganda shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income Belgium tax paid thereon in Belgiumpaid. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable attributable, as the case may be, to the income which may be taxed in Belgium.Belgium ; and 2. In the case of Belgium, double taxation shall be avoided as followsfollows : a) Where a resident of Belgium derives income income, not being dividends, interest or royalties, or owns elements of capital which is may be taxed in Lithuania Uganda in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12which are taxed there, Belgium shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. However, where the Ugandan tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income but shall reduce to a half the Belgian tax which is proportionally relating to that income, calculated as if that income was income from Belgian sources. b) Dividends derived by a company which is a resident of Belgium from a company which is a resident of Uganda, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. c) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Ugandan tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaUganda, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Uganda by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaEstonia, double taxation shall be avoided as follows: where : a) Where a resident of Lithuania Estonia derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable favourable treatment is provided in its domestic law, Lithuania Estonia shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in LithuaniaEstonia, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. b) For the purpose of sub-paragraph a), where a company that is a resident of Estonia receives a dividend from a company that is a resident of Belgium in which it owns at least 10 per cent of its shares having full voting rights, the tax paid in Belgium shall include not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the underlying profits of the company out of which the dividend was paid. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income which is taxed in Lithuania Estonia in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 1200, Belgium Xxxxxxx shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian Estonian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of LithuaniaEstonia, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaEstonia, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph subparagraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Estonia by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of or Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income or owns capital which is may be taxed in Lithuania Cyprus in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 paragraph 5 of Article 1200, Belgium Xxxxxxx shall exempt such income or capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or capital had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with sub-paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 5 of Article 12, the Lithuanian Cyprus tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of LithuaniaCyprus, and which may be taxed in Cyprus in accordance with paragraph 2 of Article 10, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, Where in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, Cyprus have been effectively deducted from the profits of that what enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Cyprus by reason of compensation for the said losses. 2. In the case of Cyprus, double taxation shall be avoided as follows: a) Where a resident of Cyprus derives income or owns capital which may be taxed in Belgium in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10 and of paragraph 2 of Article 11, Cyprus shall exempt such income or capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rte of tax which would have been applicable if such income or capital had not been exempted. b) Where a resident of Cyprus derives items of his aggregate income for Cyprus tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10 or interest taxable in accordance with paragraph 2 of Article 11, the Belgian tax paid in respect of such income shall under the provisions of Cyprus law be allowed as a credit against Cyprus tax relating to that income. c) Where a company which is a resident of Cyprus derives dividends from a company which is a resident of Belgium, and the Cyprus company owns directly at least 25 per cent of the capital of the Belgian company, the credit mentioned in sub-paragraph b) shall however take into account, under the conditions provided for in Cyprus law and in addition to the Belgian tax on such dividends, the Belgian corporate income tax payable in respect of the profits out of which the dividends are paid. d) Where, in accordance with Cyprus law, losses incurred by an enterprise carried on by a resident of Cyprus in a permanent establishment situated in Belgium have been

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaFinland, double taxation shall be avoided as follows: where : a) Where a resident of Lithuania Finland derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic lawFinland shall, Lithuania shall allow subject to the provisions of sub-paragraph b), allow: i) as a deduction from the tax on the income of that residentperson, an amount equal to the tax on income paid in Belgium; ii) as a deduction from the tax on capital of that person, an amount equal to the tax on capital paid thereon in Belgium. Such deduction in either case shall not, however, exceed that part of the tax on income tax in Lithuaniaor on capital, as computed before the deduction is given, which is attributable attributable, as the case may be, to the income or the capital which may be taxed in Belgium. b) Dividends paid by a company which is a resident of Belgium to a company which is a resident of Finland and controls directly at least 10 % of the voting power in the company paying the dividends shall be exempt from Finnish tax. c) Where in accordance with any provisions of the Convention income derived or capital owned by a resident of Finland is exempt from tax in Finland, Finland may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income or owns capital which is may be taxed in Lithuania Finland in accordance with the provisions of this the Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 6 of Article 11 and of paragraphs 2 and 6 of Article 1200, Belgium Xxxxxxx shall exempt such income or capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or capital had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where Where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph csub-paragraph e) hereinafterbelow, interest taxable in accordance with paragraph 2 or 7 6 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian fixed proportion in respect of the foreign tax levied on that income shall for which provision is made under Belgian law shall, under the conditions and at the rate provided for by such law, be allowed as a credit against Belgian tax relating to such income. c) Dividends within Where a resident of Belgium derives income which has been taxed in Finland in accordance with the meaning provisions of paragraph 3 of Article 1013, the amount of belgian tax proportionately attributable to such income shall not exceed the amount which would be charged according to Belgian law if such income were taxed as earned income derived by from sources outside Belgium and subject to foreign tax. d) Where a resident of Belgium derives income from an undivided estate which is a resident of Finland, and such income may be taxed in Finland in accordance with the Convention, the provisions of sub-paragraph a) or sub-paragraph b), as the case may be, shall apply according to the nature of the income. e) Where a company which is a resident of Belgium from owns shares in a company which is a resident of LithuaniaFinland, the dividends which are paid to it by the latter company shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. df) Where, in accordance with Belgian law, losses incurred by of an enterprise carried on by a resident of Belgium in which are attributable to a permanent establishment situated in Lithuania, Finland have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Finland by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided eliminated as follows: a) Where a resident of Belgium derives income income, not being dividends, interest or royalties, which is taxed in Lithuania China in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12Agreement, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) The exemption provided by sub-paragraph a) shall also be granted with respect to income treated as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that derives its status as such from the laws of China, where that entity has not been taxed as such by China, provided that the resident of Belgium has been taxed by China, proportionally to his participation in such entity, on the income out of which the income treated as dividends under Belgian law is paid. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of China, shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where a company which is a resident of Belgium derives from a company which is a resident of China dividends which are not exempted according to sub-paragraph c), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of China is effectively engaged in the active conduct of a business in China. In such case, such dividends are exempted under the conditions and within the limits provided for in Belgian law except those related to the fiscal regime applicable to the income out of which the dividends are paid. e) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Chinese tax levied on that income shall be allowed as a credit against Belgian tax relating to such income.income.‌‌‌ c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. dƒ) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaChina, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania China by reason of compensation for the said losses. 2. In China, double taxation shall be eliminated as follows: a) Where a resident of China derives income from Belgium the amount of tax on that income payable in Belgium in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China. b) Where a dividend is paid by a company which is a resident of Belgium to a company which is a resident of China and which owns not less than 20 per cent of the shares of the company paying the dividend, the credit shall take into account the Belgian tax paid by the company paying the dividend in respect of its income.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaQatar, double taxation shall be avoided as follows: where Where a resident of Lithuania Qatar derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed is taxable in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania then Qatar shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income tax paid thereon in Belgium. Such Belgium provided that such deduction shall not, however, not exceed that part of the income tax in Lithuaniatax, as computed before the deduction is given, which is attributable to the income which may be taxed in derived from Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income income, not being dividends, interest and royalties which is taxed in Lithuania Qatar in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12, Agreement Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Qatar tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of LithuaniaQatar, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaQatar, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Qatar by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, Armenia double taxation shall be avoided eliminated as follows: : a) where a resident of Lithuania Armenia derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania Armenia shall allow allow: i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium; ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Belgium. Such deduction in either case shall not, however, exceed that part of the income tax in Lithuaniaor capital tax, as computed before the deduction is given, which is attributable attributable, as the case may be, to the income or the capital which may be taxed in Belgium; b) where in accordance with any provision of this Convention, income derived or capital owned by a resident of Armenia is exempt from tax in Armenia, Armenia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where where a resident of Belgium derives income or owns elements of capital which is are taxed in Lithuania Armenia in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 1010 (Dividends), of paragraphs 2 and 7 of Article 11 (Interest) and of paragraphs 2 and 6 of Article 1212 (Royalties), Belgium shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted.; b) Subject subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Armenian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income.; c) Dividends within the meaning of paragraph 3 of Article 10, dividends derived by a company which is a resident of Belgium from a company which is a resident of LithuaniaArmenia, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law.; d) Wherewhere, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaArmenia, have been effectively deducted from the profits of that the enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Armenia by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of LithuaniaKazakhstan, double taxation shall be avoided as follows: where : (a) Where a resident of Lithuania Kazakhstan derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania Kazakhstan shall allow allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium; (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Belgium. Such deduction in any case shall notnot exceed the tax assessed on the same income or capital in Kazakhstan at the rates in effect therein. (b) Where a resident of Kazakhstan derives income or owns capital which, howeverin accordance with the provisions of this Convention, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may shall be taxed taxable only in Belgium, Kazakhstan may include this income or capital in the tax base but only for purposes of determining the rate of tax on such other income or capital as is taxable in Kazakhstan. 2. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income or owns elements of capital which is are taxed in Lithuania Kazakhstan in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. (b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph (c) hereinafter, interest taxable in accordance with paragraph 2 or of 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian Kazakhstan tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, Kazakhstan shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, Kazakhstan have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania Kazakhstan, by reason of compensation for the said losses.

ELIMINATION OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting States will continue to govern the assessment and taxation of income in the respective Contracting States except where express provision to the contrary is made in this Agreement. 2. In the case of LithuaniaIndia, double taxation shall be avoided as follows: where : (a) Where a resident of Lithuania India derives income which, in accordance with this Conventionthe provisions of the Agreement, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania India shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income income-tax paid thereon in BelgiumBelgium whether directly or by deduction. Such deduction shall not, however, exceed that part of the income income-tax in Lithuania, (as computed before the deduction is given, ) which is attributable to the income which may be taxed in Belgium. Further, where such resident is a company by which surtax is payable in India, the deduction in respect of income-tax paid in Belgium shall be allowed in the first instance from income-tax payable by the company in India and as to the balance, if any, from surtax payable by it in India. 2(b) Where a resident of India derives income which, in accordance with the provisions of the Agreement, shall be taxable only in Belgium, India may include this income in the tax base but shall allow as a deduction from the income-tax that part of the income which is attributable to the income derived from Belgium. 3. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which is may be taxed in Lithuania India in accordance with the provisions of this Conventionthe Agreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 6 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b(i) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where Where a resident of Belgium derives items of his aggregate income for from Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph sub-paragraph (c) hereinafter), interest taxable in accordance with paragraph 2 or 7 and 6 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian Indian tax levied on that income shall be allowed as a credit against Belgian tax relating to such incomeincome in accordance with the existing provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad. (ii) Where a resident of Belgium derives fees for technical services which have been taxed in India in accordance with paragraph 2 or 6 of Article 12, the provisions of Belgian tax law with respect to earned income derived from sources outside Belgium and subject to foreign tax shall apply. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by Where a company which is a resident of Belgium from owns shares in a company which is a resident of LithuaniaIndia, the dividends which are paid to it by the latter company and which may be taxed in India in accordance with paragraph 2 of Article 10, shall be exempt from the corporate income income-tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, Where in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, India have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania India by reason of compensation for the said losses. (e) For the purposes of sub-paragraph (b)(i), the term "Indian tax levied" shall be deemed to include any amount which would have been payable as Indian tax under the laws of India and in accordance with the provisions of the Agreement for any year but for a deduction allowed in computing the taxable income or an exemption from or a reduction of tax granted for that year under: (i) sections 10(4), 10(4B), 10(15)(iv) and 80L of the Income-tax Act, 1961 (43 of 1961), so far as they were in force on, and have not been modified since, the date of the signature of the Agreement, or have been modified only in minor respects so as not to affect their general character; or (ii) any other provision which may be enacted after the Agreement enters into force granting a deduction in computing the taxable income or an exemption from or a reduction of tax and which the competent authorities of the Contracting States agree to be for the purposes of economic development of India, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character; the competent authorities may in such a case decide as to the period for which the benefits of this clause shall apply.

ELIMINATION OF DOUBLE TAXATION. (1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. ) In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which is may be taxed in Lithuania Malta in accordance with this Agreement and which is not subject to the provisions of subparagraphs (b) or (c), or possesses elements of capital which may be taxed in Malta in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12the Agreement, Belgium shall exempt such income and such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, resident apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. (b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where When a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are from Malta: (i) dividends taxable in accordance with paragraph 2 (2) (b) of Article 10, and not exempt from Belgian tax according to in accordance with subparagraph (c) hereinafter, hereof, (ii) interest taxable in accordance with paragraph 2 paragraphs (2) or 7 (7) of Article 11, or and (iii) royalties taxable in accordance with paragraph 2 paragraphs (2) or 6 (5) of Article 12, the Lithuanian tax levied on that income Belgium shall be allowed as a allow an appropriate credit against Belgian tax relating to such income. This credit shall be the fixed proportion (quotité forfaitaire d'impôt étranger/forfaitair gedeelte van de buitenlandse belasting) for which provision is made under Belgian law. Notwithstanding the provisions of its law, Belgium shall also allow the credit provided for in this subparagraph in respect of tax chargeable on dividends, interest and royalties which are taxable in Malta by virtue of this Agreement and the law of Malta, but is temporarily remitted or reduced under special provisions designed to promote investment necessary for the economic development of Malta. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by When a company which is a resident of Belgium from owns shares or other rights in a company with share capital which is a resident of LithuaniaMalta, the dividends which are paid to it by the latter company and which are subject to Malta tax in accordance with the provisions of paragraph (2) (b) of Article 10, shall be exempt from the corporate income tax in Belgium under to the conditions and within extent that exemption would have been accorded if the limits provided for in Belgian lawtwo companies had been residents of Belgium. (d) WhereWhen, in accordance with Belgian law, losses incurred by an of a Belgian enterprise carried on by a resident of Belgium in attributable to a permanent establishment situated in Lithuania, Malta have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph subparagraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the te extent that those profits have also been exempted from tax in Lithuania by Malta by reason of compensation for the said losses. (2) In the case of Malta, double taxation shall be avoided as follows: Subject to the provisions of the law of Malta regarding the allowance of a credit against Malta tax in respect of foreign tax, where, in accordance with the provisions of this Agreement, there is included in a Malta assessment income from sources within Belgium or elements of capital situated in Belgium, the Belgian tax on such income or elements of capital shall be allowed as a credit against Malta tax payable thereon.

ELIMINATION OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting States will continue to govern the assessment and taxation of income in the respective Contracting States except where express provision to the contrary is made in this Agreement. 2. In the case of LithuaniaIndia, double taxation shall be avoided as follows: where : (a) Where a resident of Lithuania India derives income which, in accordance with this Conventionthe provisions of the Agreement, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania India shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income income-tax paid thereon in BelgiumBelgium whether directly or by deduction. Such deduction shall not, however, exceed that part of the income income-tax in Lithuania, (as computed before the deduction is given, ) which is attributable to the income which may be taxed in Belgium. Further, where such resident is a company by which surtax is payable in India, the deduction in respect of income-tax paid in Belgium shall be allowed in the first instance from income-tax payable by the company in India and as to the balance, if any, from surtax payable by it in India. 2(b) Where a resident of India derives income which, in accordance with the provisions of the Agreement, shall be taxable only in Belgium, India may include this income in the tax base but shall allow as a deduction from the income-tax that part of the income which is attributable to the income derived from Belgium. 3. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which is may be taxed in Lithuania India in accordance with the provisions of this Conventionthe Agreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 6 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b(i) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where Where a resident of Belgium derives items of his aggregate income for from Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph sub-paragraph (c) hereinafter), interest taxable in accordance with paragraph 2 or 7 and 6 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian Indian tax levied on that income shall be allowed as a credit against Belgian tax relating to such incomeincome in accordance with the existing provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad. (ii) Where a resident of Belgium derives fees for technical services which have been taxed in India in accordance with paragraph 2 or 6 of Article 12, the provisions of Belgian tax law with respect to earned income derived from sources outside Belgium and subject to foreign tax shall apply. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by Where a company which is a resident of Belgium from owns shares in a company which is a resident of LithuaniaIndia, the dividends which are paid to it by the latter company and which may be taxed in India in accordance with paragraph 2 of Article 10, shall be exempt from the corporate income income-tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, Where in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, India have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-sub- paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania India by reason of compensation for the said losses. (e) For the purposes of sub-paragraph (b)(i), the term "Indian tax levied" shall be deemed to include any amount which would have been payable as Indian tax under the laws of India and in accordance with the provisions of the Agreement for any year but for a deduction allowed in computing the taxable income or an exemption from or a reduction of tax granted for that year under: (i) sections 10(4), 10(4B), 10(15)(iv) and 80L of the Income-tax Act, 1961 (43 of 1961), so far as they were in force on, and have not been modified since, the date of the signature of the Agreement, or have been modified only in minor respects so as not to affect their general character; or (ii) any other provision which may be enacted after the Agreement enters into force granting a deduction in computing the taxable income or an exemption from or a reduction of tax and which the competent authorities of the Contracting States agree to be for the purposes of economic development of India, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character; the competent authorities may in such a case decide as to the period for which the benefits of this clause shall apply.

ELIMINATION OF DOUBLE TAXATION. 1. In Subject to the case provisions of Lithuaniathe laws of Japan regarding the allowance as a credit against Japanese tax of tax payable in any country other than Japan, double taxation shall be avoided as follows: where a resident of Lithuania Japan derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income Belgium which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income which is taxed in Lithuania in accordance with the provisions of this Convention, other than those the amount of paragraph 2 Belgian tax payable in respect of Article 10that income shall be allowed as a credit against the Japanese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of paragraphs 2 and 7 the Japanese tax which is appropriate to that income. (a) Where a resident of Article 11 and Belgium derives income, not being dividends, interest or royalties, which is taxed in Japan in accordance with the provisions of paragraphs 2 and 6 of Article 12this Convention, Belgium shall exempt such income from tax but mayif such resident is an individual, Belgium shall only exempt such income from tax to the extent that such income is effectively taxed in Japan. (b) Notwithstanding the provisions of subparagraph (a) and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels – beroepsinkomsten) that is exempted from tax in Belgium in accordance with that subparagraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had arisen in Belgium. Where in accordance with any provision of the Convention income derived by a resident of Belgium is exempted from tax in Belgium, Belgium may nevertheless, in calculating the amount of tax on the remaining income of that such resident, apply the rate of tax which would have been applicable if such income had not been exempted. b(c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of Japan shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where a company which is a resident of Belgium derives from a company which is a resident of Japan dividends which are not exempted in accordance with subparagraph (c), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of Japan is effectively engaged in the active conduct of a business in Japan. In such case, such dividends shall be exempted under the conditions provided for in Belgian law except those conditions that are related to the taxation of the company which is a resident of Japan or the income out of which the dividends are paid. The provisions of this subparagraph shall only apply to dividends paid out of income generated by the active conduct of a business and shall not apply to the extent that the company that is a resident of Japan has deducted, or may deduct, the dividends from its profits. For the purposes of this subparagraph, a company shall not be considered to be effectively engaged in the active conduct of a business in Japan where such company is an investment company, a financing company (other than a bank) or a treasury company or where such company holds any portfolio investment or any copyright, patent, trade mark, design, model, plan, secret formula or process which represents in the aggregate more than a third of its assets and such holding is not part of the active conduct of a business. (e) Where a company which is a resident of Belgium derives from a company which is a resident of Japan dividends which are included in its aggregate income for Belgian tax purposes and which are not exempted from the corporate income tax according to subparagraph (c) or (d), the Japanese tax charged on such dividends in accordance with paragraph 2 of Article 10 shall be allowed as a credit against Belgian tax relating to such dividends. The credit allowed shall not exceed that part of the Belgian tax which is proportionally relating to such dividends. (f) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Japanese tax levied charged on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d(g) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, Japan have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph subparagraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that permanent establishment to the extent that those profits have also been exempted from tax in Lithuania Japan by reason of compensation for the said deduction of such losses.

ELIMINATION OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting States will continue to govern the assessment and taxation of income in the respective Contracting States except where express provision to the contrary is made in this Agreement. 2. In the case of LithuaniaIndia, double taxation shall be avoided as follows: where follows:- a. Where a resident of Lithuania India derives income which, in accordance with this Conventionthe provisions of the Agreement, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania India shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income income-tax paid thereon in BelgiumBelgium whether directly or by deduction. Such deduction shall not, however, exceed that part of the income income-tax in Lithuania, (as computed before the deduction is given, ) which is attributable to the income which may be taxed in Belgium. Further, where such resident is a company by which surtax is payable in India, the deduction in respect of income-tax paid in Belgium shall be allowed in the first instance from income-tax payable by the company in India and as to the balance, if any, from surtax payable by it in India. 2b. Where a resident of India derives income which, in accordance with the provisions of the Agreement, shall be taxable only in Belgium, India may include this income in the tax base but shall allow as a deduction from the income-tax that part of the income-tax which is attributable to the income derived from Belgium. 3. In the case of Belgium, double taxation shall be avoided as follows:follows:- a) a. Where a resident of Belgium Belgium, derives income which is may be taxed in Lithuania India in accordance with the provisions of this Conventionthe Agreement, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 6 of Article 11 and of paragraphs 2 and 6 of Article 1200, Belgium Xxxxxxx shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where i. Where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph sub-paragraph (c) hereinafter), interest taxable in accordance with paragraph 2 or 7 6 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian Indian tax levied on that income shall be allowed as a credit against Belgian tax relating to such incomeincome in accordance with the existing provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad. c) Dividends within the meaning ii. Where a resident of Belgium derive; fees for technical services which have been taxed in India in accordance with paragraph 3 2 or 6 of Article 1012, the provisions of Belgian tax law with respect to earned income derived by from sources outside Belgium and subject to foreign tax shall apply. c. Where a company which is a resident of Belgium from owns shares in a company which is a resident of LithuaniaIndia, the dividends which are paid to it by the latter company and which may be taxed in India in accordance with paragraph 2 of Article 10, shall be exempt from the corporate income income-tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, d. Where in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, India have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania India by reason of compensation for the said losses. e. For the purposes of sub-paragraph (b)(i) the term "Indian tax levied" shall be deemed to include any amount which would have been payable as Indian tax under the laws of India and in accordance with the provisions of the Agreement for any year but for a deduction allowed in computing the taxable income or an exemption from or a reduction of tax granted for that year under i. sections 10(4), 10(4B), 10(15)(iv) and 80L of the Income-tax Act, 1961 (43 of 1961), so far as they were in force on, and have not been modified since, the date of the signature of the Agreement, or have been modified only in minor respects so as not to affect their general character; or

ELIMINATION OF DOUBLE TAXATION. 1. In The laws in force in either of the case Contracting States shall continue to govern the taxation of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with the respective Contracting States except when express provision to the contrary is made in this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income which is may be taxed in Lithuania Sri Lanka in accordance with the provisions of this the Convention, other than those whether or not it is taxed, and which is not subject to the provisions of paragraph 2 of Article 10, of sub-paragraphs 2 (b) and 7 of Article 11 and of paragraphs 2 and 6 of Article 12(c) below, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of the tax which would have been applicable if such income had not been exempted.; (b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where Where a resident of Belgium derives items derives: -- dividends dealt with in paragraph 2 of his aggregate income for Article 10 and not covered by sub-paragraph (c) below, -- interest dealt with in paragraphs 2 or 7 of Article 11, -- royalties dealt with in paragraphs 2 or 6 of Article 12, Belgium shall allow an appropriate credit against Belgian tax purposes relating to such income. This credit shall be the fixed proportion for which provision is made under Belgian law. Notwithstanding the provisions of this law, Belgium shall also allow the credit provided for in this sub-paragraph in respect of tax which may be charged in Sri Lanka on dividends, interest and royalties by virtue of the Convention and the law of Sri Lanka but which is temporarily remitted or reduced under special provisions designed to promote the economic development of Sri Lanka; (c) where a company which is a resident of Belgium owns shares in a company with share capital which is a resident of Sri Lanka, the dividends which are dividends taxable paid to it by the latter company and which may be taxed in Sri Lanka in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those exemption would have been accorded if the two companies had been residents of Belgium; (d) notwithstanding sub-paragraph (a) above, Belgian tax may be charged on income liable to Sri Lanka tax to the extent that such income has not been charged in Sri Lanka because of the set of losses also deducted, in respect of any accounting period, from income taxable in Belgium. 3. Subject to the provisions of the law of Sri Lanka regarding the allowance as a credit against Sri Lanka tax of tax payable in a territory outside Sri Lanka (which shall not affect the general principle hereof), Belgian tax payable under the law of Belgium and in accordance with the Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Belgium (excluding in the case of a dividend, tax payable in respect of the profits have also been exempted out of which the dividend is paid) shall be allowed as a credit against any Sri Lanka tax computed by reference to the same items of income. Provided that such credit shall not exceed Sri Lanka tax (as computed before allowing any such credit), which is appropriate to the income derived from tax in Lithuania by reason of compensation for the said lossessources within Belgium.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium. 2. In the case of Belgium, double taxation shall be avoided eliminated as follows: a) Where a resident of Belgium derives income income, not being dividends, interest or royalties, which is taxed in Lithuania China in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12Agreement, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. b) The exemption provided by sub-paragraph a) shall also be granted with respect to income treated as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that derives its status as such from the laws of China, where that entity has not been taxed as such by China, provided that the resident of Belgium has been taxed by China, proportionally to his participation in such entity, on the income out of which the income treated as dividends under Belgian law is paid. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of China, shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where a company which is a resident of Belgium derives from a company which is a resident of China dividends which are not exempted according to sub-paragraph c), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of China is effectively engaged in the active conduct of a business in China. In such case, such dividends are exempted under the conditions and within the limits provided for in Belgian law except those related to the fiscal regime applicable to the income out of which the dividends are paid. e) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12royalties, the Lithuanian Chinese tax levied on that income shall be allowed as a credit against Belgian tax relating to such income.income.‌‌‌ c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. df) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in LithuaniaChina, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Lithuania China by reason of compensation for the said losses. 2. In China, double taxation shall be eliminated as follows: a) Where a resident of China derives income from Belgium the amount of tax on that income payable in Belgium in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China. b) Where a dividend is paid by a company which is a resident of Belgium to a company which is a resident of China and which owns not less than 20 per cent of the shares of the company paying the dividend, the credit shall take into account the Belgian tax paid by the company paying the dividend in respect of its income.