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Republic of Lithuania Law on the Ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

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republic of litHuania

law

on the ratification of The Multilateral Convention to Implement

Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

 

14 June 2018   No XIII-1271

Vilnius

 

 

 

Article 1. Ratification of the Convention

The Seimas of the Republic of Lithuania, acting pursuant to point 16 of Article 67 and Article 138(1)(6) of the Constitution of the Republic of Lithuania, and having regard to Decree No 1K-1212 of the President of the Republic of Lithuania of 2 February 2018, hereby ratifies the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (hereinafter: the ‘Convention’), signed on behalf of the Republic of Lithuania at Paris on 7 June 2017, with reservations and notifications of the Republic of Lithuania (made pursuant to the Convention) as specified in the Annex to this Law.

 

I promulgate this Law passed by the Seimas of the Republic of Lithuania.

 

 

 

President of the Republic                                                                                       Dalia Grybauskaitė

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Annex to

the Law of the Republic of Lithuania on

the Ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

 

RESERVATIONS AND NOTIFICATIONS OF THE REPUBLIC OF LITHUANIA

 

Article 2 – Interpretation of Terms

 

Notification - Agreements Covered by the Convention

 

Pursuant to Article 2(1)(a)(ii) of the Convention, the Republic of Lithuania wishes the following agreements to be covered by the Convention:

 

No

Title

Other

Contracting Jurisdiction

Original/

Amending

Instrument

Date of Signature

Date of Entry into Force

1

Convention between the Republic of Lithuania and the Republic of Armenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

 

Armenia

Original

13-03-2000

26-02-2001

2

Convention between the Republic of Lithuania and the Republic of Austria for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

Austria

Original

06-04-2005

17-11-2005

3

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Azerbaijan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion

with respect to Taxes on Income and on Capital

Azerbaijan

Original

02-04-2004

13-11- 2004

4

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Belarus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

 

Belarus

Original

18-07-1995

26-06-1996

5

Convention between the Government of the Republic of Lithuania and the Government of the Kingdom of  Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income 

Belgium

Original

26-11-1998

 

05-05-2003

6

Convention between the Republic of Lithuania and the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Bulgaria

Original

09-05-2006

 

27-12-2006

 

7

Convention between the Government of the Republic of Lithuania and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Canada

Original

29-08-1996

12-12-1997

8

Agreement between the Government of the Republic of Lithuania and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

China

Original

03-06-1996

18-10-1996

9

Agreement between the Government of the Republic of Lithuania and the Government of the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Croatia

Original

04-05-2000

30-03-2001

10

Convention between the Republic of Lithuania and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Czech Republic

Original

27-10-1994

08-08-1995

11

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Cyprus

Original

21-06- 2013

17-04- 2014

12

Convention between the Kingdom of Denmark and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Denmark

Original

13-10-1993

30-12-1993

13

Convention between the Republic of Estonia and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Estonia

Original

21-10-2004

08-02-2006

14

Convention between the Republic of Finland and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Finland

Original

30-04-1993

30-12-1993

15

Convention between the Government of the Republic of Lithuania and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

France

Original

07-07-1997

01-05-2001

16

Convention between the Republic of Lithuania And Georgia for the Avoidance of Double Taxation

and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Georgia

Original

11-09-2003

20-07-2004

17

Agreement between the Federal Republic of Germany and the Republic of Lithuania for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

Germany

Original

22-07-1997

11-11-1998

18

Convention between the Government of The Republic of Lithuania and the Government of the Hellenic Republic for the Avoidance of Double Taxation

and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Greece

Original

15-05-2002

05-12-2005

19

Convention between the Republic of Lithuania and the Republic of Hungary for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Hungary

Original

12-05-2004

22-12-2004

20

Convention between the Republic of Lithuania and the Republic of Iceland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Iceland

Original

13-06-1998

17-06-1999

21

Agreement between the Government of the Republic of Lithuania and the Government of the Republic of India for the Avoidance of Double Taxation and Prevention of Fiscal Evasion

with respect to Taxes on Income and on Capital

India

Original

26-07-2011

10-07-2012

22

Convention between the Government of Ireland and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains

Ireland

Original

18-11-1997

05-06-1998

23

Convention between the Government of the Republic of Lithuania and the Government of the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Israel

Original

11-05-2006

01-12-2006

24

Convention between the Government of the Republic of Lithuania and the Government of the Italian Republic for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital and the Prevention of Fiscal Evasion

Italy

Original

04-04-1996

03-06-1999

25

Convention between the Republic of Lithuania and the Republic of Kazakhstan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Kazakhstan

Original

07-03- 1997

11-12- 1997

26

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Korea for the Avoidance of Double Taxation

and the Prevention of Fiscal Evasion with respect to Taxes on Income

Korea

Original

20-04-2006

14-07-2007

27

Agreement between the Government of the Republic of Lithuania

and the Government of the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Kuwait

Original

18-04-2013

08-09-2017

28

Agreement between the Government of the Republic of Lithuania

and the Government of the Kyrgyz Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Kyrgyzstan

Original

15-05-2008

20-06-2013

29

Convention between the Republic of Latvia and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Latvia

Original

17-12-1993

30-12-1994

30

Convention between the Government of the Republic of Lithuania and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With respect to Taxes on Income and on Capital

Luxembourg

Original

22-11-2004

14-04-2006

Amending

Instrument

20-06-2014

11-12-2015

31

Agreement between the Government of the Republic of Lithuania

and the Government of the Republic of Macedonia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Macedonia

Original

29-08-2007

27-08-2008

32

Convention between the Government of Malta and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Malta

Original

17-05-2001

02-02-2004

33

Convention between the Government of the Republic of Lithuania and the Government of the United Mexican States  for the Avoidance of Double Taxation

and the Prevention of Fiscal Evasion with respect to Taxes on Income

Mexico

Original

23-02-2012

29-11-2012

34

Agreement between the Government of the Republic of Lithuania and the Government of the Republic of Moldova for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Moldova 

Original

18-02- 1998

07-09- 1998

35

Convention between the Government of the Republic of Lithuania and the Government of the Kingdom of Morocco for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Morocco

Original

19-04-2013

-

36

Convention between the Kingdom of the Netherlands and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Netherlands

Original

16-06-1999

31-08-2000

37

Convention between the Kingdom of Norway and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Norway

Original

27-04-1993

30-12-1993

38

Agreement between the Government of the Republic of Poland and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Poland

Original

20-01-1994

19-07-1994

39

Convention between the Portuguese Republic and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Portugal

Original

14-02-2002

26-02-2003

40

Convention between the Republic of Lithuania and Romania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Romania

Original

26-11-2001

15-07-2002

41

Agreement between the Government of the Russian Federation and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Russia

Original

29-06-1999

05-05-2005

42

Convention between the Government of the Republic of Lithuania and the  Government of the Republic of Serbia for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

Serbia

Original

28-08- 2007

12-06- 2009

43

Agreement between the Government of the Republic of Lithuania and the Government of The Republic of Singapore for the Avoidance of Double Taxation

and the Prevention of Fiscal Evasion with respect to Taxes on Income

Singapore

Original

18-11-2003

28-06-2004

44

Convention between the Republic of Lithuania and the Slovak Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Slovakia

Original

15-03-2001

16-12-2002

45

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Slovenia

Original

23-05-2000

01-02-2002

46

Convention between the Kingdom of Spain and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Spain

Original

22-07-2003

26-12-2003

47

Convention between the Kingdom of Sweden and the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Sweden

Original

27-09-1993

30-12-1993

48

Convention between the Government of the Republic of Lithuania and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

Switzerland

Original

27-05-2002

18-12-2002

49

Agreement between the Government of the Republic of Lithuania and the Government of The Republic of Turkey For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Turkey

Original

24-11-1998

17-05-2000

50

Agreement between the Government of the Republic of Lithuania and the Government of Turkmenistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Turkmenistan

Original

18-06-2013

10-12-2014

51

Convention between the Government of the Republic of Lithuania and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Ukraine

Original

23-09- 1996

25-12- 1997

52

Agreement between Government of the Republic of Lithuania and the Government of the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

United Arab Emirates

Original

30-06-2013

19-12-2014

53

Convention between the Government of the Republic of Lithuania and the Government of the United Kingdom of Great Britain And Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains

United Kingdom

Original

19-03-2001

04-02-2002

Amending

Instrument

21-05-2002

28-11-2002

54

Convention between the Government of the United States of America and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

United States

Original

15-01-1998

30-12-1999

55

Convention between the Government of the Republic of Lithuania and the Government of the Republic of Uzbekistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Uzbekistan

Original

18-02-2002

11-11-2002

 


Article 3 Transparent Entities

 

Reservation

 

Pursuant to Article 3(5)(a) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 3 not to apply to its Covered Tax Agreements.

 

 

Article 4 – Dual Resident Entities

 

Reservation

 

Pursuant to Article 4(3)(a) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements.

 

 

Article 6 – Purpose of a Covered Tax Agreement

 

Notification of Existing Preamble Language in Listed Agreements

 

Pursuant to Article 6(5) of the Convention, the Republic of Lithuania considers that the following agreements are not within the scope of a reservation under Article 6(4) and contain preamble language described in Article 6(2). The text of the relevant preambular paragraph is identified below.

 

Listed

Agreement

Number

Other

Contracting

Jurisdiction

Preamble Text

1

Armenia

< proceeding from the intention to promote and strengthen economical, scientific, technical and cultural relations between both Contracting States and> in order to avoid double taxation and prevent fiscal evasion with respect to taxes on income and on capital and exclude tax discrimination, <decided to conclude this Convention>

2

Austria

desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital,

3

Azerbaijan

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

4

Belarus

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

5

Belgium

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

6

Bulgaria

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital <in order to promote and strengthen the economic relations between the two States,>

7

Canada

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

8

China

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

9

Croatia

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

10

Czech Republic

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

11

Cyprus

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

12

Denmark

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

13

Estonia

wishing to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

14

Finland

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

15

France

désireux de conclure une Convention en vue d'éviter les doubles impositions et de prévenir l'évasion et la fraude fiscales en matière d'impôts sur le revenu et sur la fortune,

 

16

Georgia

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

18

Greece

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

19

Hungary

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

20

Iceland

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

21

India

desiring to conclude an Agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital <and with a view to promoting economic cooperation between the two Contracting States>,

22

Ireland

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains,

23

Israel

DESIRING to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

24

Italy

Desiring to conclude a Convention to avoid double taxation with respect to taxes on income and on capital and to prevent fiscal evasion,

25

Kazakhstan

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

26

Korea

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

27

Kuwait

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

28

Kyrgyzstan

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

29

Latvia

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

30

Luxembourg

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

31

Macedonia

desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

32

Malta

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

33

Mexico

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

34

Moldova 

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

35

Morocco

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

36

Netherlands

Desiring to conclude a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

37

Norway

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

38

Poland

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

39

Portugal

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

40

Romania

desiring <to promote and strengthen the economic relations> by concluding a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

41

Russia

desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital <and with a view to promote economic cooperation between the two states>,

42

Serbia

Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital,

43

Singapore

Desiring to conclude Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

44

Slovakia

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

45

Slovenia

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

46

Spain

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

47

Sweden

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

48

Switzerland

Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital,

49

Turkey

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

50

Turkmenistan

desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

51

Ukraine

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,

<And confirming their endeavour to the development and deepening of mutual economic relations,>

52

United Arab Emirates

Desiring to promote their mutual economic relations through the conclusion between them of an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income,

53

United Kingdom

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains;

54

United States

desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

55

Uzbekistan

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income <and on capital and with a view to promote economic cooperation between the two countries>,

 

 

Article 7 – Prevention of Treaty Abuse

 

Notification of Choice of Optional Provisions

 

Pursuant to Article 7(17)(b) of the Convention, the Republic of Lithuania hereby chooses to apply Article 7(4).

 

Notification of Existing Provisions in Listed Agreements

 

Pursuant to Article 7(17)(a) of the Convention, the Republic of Lithuania considers that the following agreements are not subject to a reservation under Article 7(15)(b) and contain a provision described in Article 7(2). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

5

Belgium

Article 29

7

Canada

Article 28(3)

13

Estonia

Article 30

21

India

Article 30(1)

24

Italy

Article 30(1)

25

Kazakhstan

Article (28)

29

Latvia

Article (30)

31

Macedonia

Article 28

32

Malta

Article 27(3)

33

Mexico

Article 23

36

Netherlands

Article 10(8)

41

Russia

Article 28

43

Singapore

Article 22(3), (4)

51

Ukraine

Article 25

52

United Arab Emirates

Article 30

53

United Kingdom

Articles 10(6), 11(8), 12(7),22 (4),  25(2)

55

Uzbekistan

Article 28

 

 

Article 8 – Dividend Transfer Transactions

 

Reservation

 

Pursuant to Article 8(3)(a) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 8 not to apply to its Covered Tax Agreements.

 

 

Article 9 – Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property

 

Reservation

 

Pursuant to Article 9(6)(a) of the Convention, the Republic of Lithuania reserves the right for Article 9(1) not to apply to its Covered Tax Agreements.

 

 

Article 10 – Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions

 

Reservation

 

Pursuant to Article 10(5)(a) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 10 not to apply to its Covered Tax Agreements.

 

 

Article 11 – Application of Tax Agreements to Restrict a Party’s Right to Tax its Own Residents

 

Reservation

 

Pursuant to Article 11(3)(a) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 11 not to apply to its Covered Tax Agreements.

 

 

Article 12 – Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies

 

Notification of Existing Provisions in Listed Agreements

 

Pursuant to Article 12(5) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision described in Article 12(3)(a). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 5(5)

2

Austria

Article 5(5)

3

Azerbaijan

Article 5(5)

4

Belarus

Article 5(5)

5

Belgium

Article 5(5)

6

Bulgaria

Article 5(5)

7

Canada

Article 5(5)

8

China

Article 5(5)

9

Croatia

Article 5(5)

10

Czech Republic

Article 5(5)

11

Cyprus

Article 5(5)

12

Denmark

Article 5(5)

13

Estonia

Article 5(5)

14

Finland

Article 5(5)

15

France

Article 5(5)

16

Georgia

Article 5(5)

17

Germany

Article 5(5)

18

Greece

Article 5(5)

19

Hungary

Article 5(5)

20

Iceland

Article 5(5)

21

India

Article 5(5) (a)

22

Ireland

Article 5(5)

23

Israel

Article 5(5)

24

Italy

Article 5(4)

25

Kazakhstan

Article 5(5)

26

Korea

Article 5(5)

27

Kuwait

Article 5(5)

28

Kyrgyzstan

Article 5(5)

29

Latvia

Article 5(5)

30

Luxembourg

Article 5(5)

31

Macedonia

Article 5(5)

32

Malta

Article 5(5)

33

Mexico

Article 5(5)

34

Moldova 

Article 5(5)

35

Morocco

Article 5(5)

36

Netherlands

Article 5(5)

37

Norway

Article 5(5)

38

Poland

Article 5(5)

39

Portugal

Article 5(5)

40

Romania

Article 5(6)

41

Russia

Article 5(5)

42

Serbia

Article 5(5)

43

Singapore

Article 5(5)

44

Slovakia

Article 5(5)

45

Slovenia

Article 5(5)

46

Spain

Article 5(5)

47

Sweden

Article 5(5)

48

Switzerland

Article 5(5)

49

Turkey

Article 5(5)

50

Turkmenistan

Article 5(5)

51

Ukraine

Article 5(5)

52

United Arab Emirates

Article 5(6)

53

United Kingdom

Article 5(5)

54

United States

Article 5(5)

55

Uzbekistan

Article 5(5)

 

 

Pursuant to Article 12(6) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision described in Article 12(3)(b). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 5(6)

2

Austria

Article 5(6)

3

Azerbaijan

Article 5(6)

4

Belarus

Article 5(6)

5

Belgium

Article 5(6)

6

Bulgaria

Article 5(6)

7

Canada

Article 5(6)

8

China

Article 5(6)

9

Croatia

Article 5(6)

10

Czech Republic

Article 5(6)

11

Cyprus

Article 5(6)

12

Denmark

Article 5(6)

13

Estonia

Article 5(6)

14

Finland

Article 5(6)

15

France

Article 5(6)

16

Georgia

Article 5(6)

17

Germany

Article 5(6)

18

Greece

Article 5(6)

19

Hungary

Article 5(6)

20

Iceland

Article 5(6)

21

India

Article 5(6)

22

Ireland

Article 5(6)

23

Israel

Article 5(6)

24

Italy

Article 5(5)

25

Kazakhstan

Article 5(6)

26

Korea

Article 5(6)

27

Kuwait

Article 5(6)

28

Kyrgyzstan

Article 5(6)

29

Latvia

Article 5(6)

30

Luxembourg

Article 5(6)

31

Macedonia

Article 5(6)

32

Malta

Article 5(6)

33

Mexico

Article 5(6)

34

Moldova 

Article 5(6)

35

Morocco

Article 5(6)

36

Netherlands

Article 5(6)

37

Norway

Article 5(6)

38

Poland

Article 5(6)

39

Portugal

Article 5(6)

40

Romania

Article 5(7)

41

Russia

Article 5(6)

42

Serbia

Article 5(6)

43

Singapore

Article 5(6)

44

Slovakia

Article 5(6)

45

Slovenia

Article 5(6)

46

Spain

Article 5(6)

47

Sweden

Article 5(6)

48

Switzerland

Article 5(6)

49

Turkey

Article 5(6)

50

Turkmenistan

Article 5(6)

51

Ukraine

Article 5(6)

52

United Arab Emirates

Article 5(7)

53

United Kingdom

Article 5(6)

54

United States

Article 5(6)

55

Uzbekistan

Article 5(6)


 

Article 13 – Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions

 

 

Notification of Choice of Optional Provisions

 

Pursuant to Article 13(7) of the Convention, the Republic of Lithuania hereby chooses to apply Option B under Article 13(1).

 

 

Notification of Existing Provisions in Listed Agreements

 

Pursuant to Article 13(7) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision described in Article 13(5)(a). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 5(4)

2

Austria

Article 5(4)

3

Azerbaijan

Article 5(4)

4

Belarus

Article 5(4)

5

Belgium

Article 5(4)

6

Bulgaria

Article 5(4)

7

Canada

Article 5(4)

8

China

Article 5(4)

9

Croatia

Article 5(4)

10

Czech Republic

Article 5(4)

11

Cyprus

Article 5(4)

12

Denmark

Article 5(4)

13

Estonia

Article 5(4)

14

Finland

Article 5(4)

15

France

Article 5(4)

16

Georgia

Article 5(4)

17

Germany

Article 5(4)

18

Greece

Article 5(4)

19

Hungary

Article 5(4)

20

Iceland

Article 5(4)

21

India

Article 5(4)

22

Ireland

Article 5(4)

23

Israel

Article 5(4)

24

Italy

Article 5(3)

25

Kazakhstan

Article 5(4)

26

Korea

Article 5(4)

27

Kuwait

Article 5(4)

28

Kyrgyzstan

Article 5(4)

29

Latvia

Article 5(4)

30

Luxembourg

Article 5(4)

31

Macedonia

Article 5(4)

32

Malta

Article 5(4)

33

Mexico

Article 5(4)

34

Moldova 

Article 5(4)

35

Morocco

Article 5(4)

36

Netherlands

Article 5(4)

37

Norway

Article 5(4)

38

Poland

Article 5(4)

39

Portugal

Article 5(4)

40

Romania

Article 5(4)

41

Russia

Article 5(4)

42

Serbia

Article 5(4)

43

Singapore

Article 5(4)

44

Slovakia

Article 5(4)

45

Slovenia

Article 5(4)

46

Spain

Article 5(4)

47

Sweden

Article 5(4)

48

Switzerland

Article 5(4)

49

Turkey

Article 5(4)

50

Turkmenistan

Article 5(4)

51

Ukraine

Article 5(4)

52

United Arab Emirates

Article 5(5)

53

United Kingdom

Article 5(4)

54

United States

Article 5(4)

55

Uzbekistan

Article 5(4)

 

 


 

Article 14 – Splitting-up of Contracts

 

Reservation

 

Pursuant to Article 14(3)(b) of the Convention, the Republic of Lithuania reserves the right for the entirety of Article 14 not to apply with respect to provisions of its Covered Tax Agreements relating to the exploration for or exploitation of natural resources. The following agreements contain provisions that are within the scope of this reservation.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 5(3b)

2

Austria

Article 21

3

Azerbaijan

Article 21

5

Belgium

Article 21

6

Bulgaria

Article 5 (3c)

7

Canada

Article 29

8

China

Article 22

9

Croatia

Article 21

11

Cyprus

Article 21

12

Denmark

Article 21

13

Estonia

Article 29

14

Finland

Article 21

16

Georgia

Article 21

17

Germany

Article 20a

18

Greece

Article 21

19

Hungary

Article 5(b)

20

Iceland

Article 21

21

India

Article 5(c)

22

Ireland

Article 22

23

Israel

Article 5 (3b)

24

Italy

Article 22

25

Kazakhstan

Article 21

27

Kuwait

Article 5(3c)

28

Kyrgyzstan

Article 21

29

Latvia

Article 29

30

Luxembourg

Article 21

31

Macedonia

Article 5(3c)

32

Malta

Article 21

33

Mexico

Article 21

34

Moldova

Article 5 (3b)

35

Morocco

Article 5(3c)

36

Netherlands

Article 25

37

Norway

Article 21

38

Poland

Article 22

39

Portugal

Article 22

40

Romania

Protocol

41

Russia

Article 21

42

Serbia

Article 5 (3 (2))

43

Slovakia

Protocol (para. III)

44

Slovenia

Article 5 (3b)

46

Spain

Article 21

47

Sweden

Article 21

51

Ukraine

Article 21

52

United Arab Emirates

Article 22

53

United Kingdom

Article 23

54

United States

Article 21

55

Uzbekistan

Article 21

 

 

Article 16 – Mutual Agreement Procedure

 

Notification of Existing Provisions in Listed Agreements

 

Pursuant to Article 16(6)(a) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision described in Article 16(4)(a)(i). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 25(1), first sentence

2

Austria

Article 26(1), first sentence

3

Azerbaijan

Article 26(1), first sentence

4

Belarus

Article 24(1), first sentence

5

Belgium

Article 25(1), first sentence

6

Bulgaria

Article 26(1), first sentence

7

Canada

Article 25(1), first sentence

8

China

Article 27(1), first sentence

9

Croatia

Article 25(1), first sentence

10

Czech Republic

Article 25(1), first sentence

11

Cyprus

Article 25(1), first sentence

12

Denmark

Article 26(1), first sentence

13

Estonia

Article 25(1), first sentence

14

Finland

Article 26(1), first sentence

15

France

Article 25(1), first sentence

16

Georgia

Article 26(1), first sentence

17

Germany

Article 25(1), first sentence

18

Greece

Article 26(1), first sentence

19

Hungary

Article 25(1), first sentence

20

Iceland

Article 26(1), first sentence

21

India

Article 26(1), first sentence

22

Ireland

Article 25(1), first sentence

23

Israel

Article 25(1), first sentence

24

Italy

Article 27(1), first sentence

25

Kazakhstan

Article 26(1), first sentence

26

Korea

Article 25(1), first sentence

27

Kuwait

Article 25(1), first sentence

28

Kyrgyzstan

Article 25(1), first sentence

29

Latvia

Article 25(1), first sentence

30

Luxembourg

Article 26(1), first sentence

31

Macedonia

Article 25(1), first sentence

32

Malta

Article 25(1), first sentence

33

Mexico

Article 26(1), first sentence

34

Moldova 

Article 25(1), first sentence

35

Morocco

Article 25(1), first sentence

36

Netherlands

Article 27(1), first sentence

37

Norway

Article 26(1), first sentence

38

Poland

Article 27(1), first sentence

39

Portugal

Article 26(1), first sentence

40

Romania

Article 27(1), first sentence

41

Russia

Article 26(1), first sentence

42

Serbia

Article 26(1), first sentence

43

Singapore

Article 25(1), first sentence

44

Slovakia

Article 25(1), first sentence

45

Slovenia

Article 26(1), first sentence

46

Spain

Article 26(1), first sentence

47

Sweden

Article 26(1), first sentence

48

Switzerland

Article 25(1), first sentence

49

Turkey

Article 24(1), first sentence

50

Turkmenistan

Article 25(1), first sentence

51

Ukraine

Article 27(1), first sentence

52

United Arab Emirates

Article 26(1), first sentence

53

United Kingdom

Article 28(1)

54

United States

Article 26(1), first sentence

55

Uzbekistan

Article 26(1), first sentence

 

 

Pursuant to Article 16(6)(b)(i) of the Convention, the Republic of Lithuania considers that the following agreement contains a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is shorter than three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

7

Canada

Article 25(1), second sentence

 

 

Pursuant to Article 16(6)(b)(ii) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is at least three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 25(1), second sentence

2

Austria

Article 26(1), second sentence

3

Azerbaijan

Article 26(1), second sentence

4

Belarus

Article 24(1), second sentence

5

Belgium

Article 25(1), second sentence

6

Bulgaria

Article 26(1), second sentence

8

China

Article 27(1), second sentence

9

Croatia

Article 25(1), second sentence

10

Czech Republic

Article 25(1), second sentence

11

Cyprus

Article 25(1), second sentence

12

Denmark

Article 26(1), second sentence

13

Estonia

Article 25(1), second sentence

14

Finland

Article 26(1), second sentence

15

France

Article 25(1), second sentence

16

Georgia

Article 26(1), second sentence

17

Germany

Article 25(1), second sentence

18

Greece

Article 26(1), second sentence

19

Hungary

Article 25(1), second sentence

20

Iceland

Article 26(1), second sentence

21

India

Article 26(1), second sentence

22

Ireland

Article 25(1), second sentence

23

Israel

Article 25(1), second sentence

24

Italy

Article 27(1), second sentence

25

Kazakhstan

Article 26(1), second sentence

26

Korea

Article 25(1), second sentence

27

Kuwait

Article 25(1), second sentence

28

Kyrgyzstan

Article 25(1), second sentence

29

Latvia

Article 25(1), second sentence

30

Luxembourg

Article 26(1), second sentence

31

Macedonia

Article 25(1), second sentence

32

Malta

Article 25(1), second sentence

33

Mexico

Article 26(1), second sentence

34

Moldova 

Article 25(1), second sentence

35

Morocco

Article 25(1), second sentence

36

Netherlands

Article 27(1), second sentence

37

Norway

Article 26(1), second sentence

38

Poland

Article 27(1), second sentence

39

Portugal

Article 26(1), second sentence

40

Romania

Article 27(1), second sentence

41

Russia

Article 26(1), second sentence

42

Serbia

Article 26(1), second sentence

43

Singapore

Article 25(1), second sentence

44

Slovakia

Article 25(1), second sentence

45

Slovenia

Article 26(1), second sentence

46

Spain

Article 26(1), second sentence

47

Sweden

Article 26(1), second sentence

48

Switzerland

Article 25(1), second sentence

49

Turkey

Article 24(1), second sentence

50

Turkmenistan

Article 25(1), second sentence

51

Ukraine

Article 27(1), second sentence

52

United Arab Emirates

Article 26(1), second sentence

54

United States

Article 26(1), second sentence

55

Uzbekistan

Article 26(1), second sentence

 

 

Pursuant to Article 16(6)(c)(ii) of the Convention, the Republic of Lithuania considers that the following agreements do not contain a provision described in Article 16(4)(b)(ii).

 

Listed Agreement Number

Other Contracting Jurisdiction

7

Canada

24

Italy

33

Mexico

48

Switzerland

53

United Kingdom

 

 

Pursuant to Article 16(6)(d)(ii) of the Convention, the Republic of Lithuania considers that the following agreements do not contain a provision described in Article 16(4)(c)(ii).

 

Listed Agreement Number

Other Contracting Jurisdiction

5

Belgium

22

Ireland

24

Italy

51

Ukraine

53

United Kingdom

 


 

Article 17 – Corresponding Adjustments

 

Notification of Existing Provisions in Listed Agreements

 

Pursuant to Article 17(4) of the Convention, the Republic of Lithuania considers that the following agreements contain a provision described in Article 17(2). The article and paragraph number of each such provision is identified below.

 

Listed Agreement Number

Other Contracting Jurisdiction

Provision

1

Armenia

Article 9(2)

2

Austria

Article 9(2)

3

Azerbaijan

Article 9(2)

4

Belarus

Article 9(2)

5

Belgium

Article 9(2)

6

Bulgaria

Article 9(2)

7

Canada

Article 9(2)

8

China

Article 9(2)

9

Croatia

Article 9(2)

11

Cyprus

Article 9(2)

12

Denmark

Article 9(2)

13

Estonia

Article 9(2)

14

Finland

Article 9(2)

15

France

Article 9(2)

16

Georgia

Article 9(2)

18

Greece

Article 9(2)

19

Hungary

Article 9(2)

20

Iceland

Article 9(2)

21

India

Article 9(2)

22

Ireland

Article 9(2)

23

Israel

Article 9(2)

24

Italy

Protocol (g)

25

Kazakhstan

Article 9(2)

26

Korea

Article 9(2)

27

Kuwait

Article 9(2)

28

Kyrgyzstan

Article 9(2)

29

Latvia

Article 9(2)

30

Luxembourg

Article 9(2)

31

Macedonia

Article 9(2)

32

Malta

Article 9(2)

33

Mexico

Article 9(2)

34

Moldova 

Article 9(2)

35

Morocco

Article 9(2)

36

Netherlands

Article 9(2)

37

Norway

Article 9(2)

38

Poland

Article 9(2)

39

Portugal

Article 9(2)

40

Romania

Article 9(2)

41

Russia

Article 9(2)

42

Serbia

Article 9(2)

43

Singapore

Article 9(2)

44

Slovakia

Article 9(2)

45

Slovenia

Article 9(2)

46

Spain

Article 9(2)

47

Sweden

Article 9(2)

48

Switzerland

Article 9(2)

49

Turkey

Article 9(2)

50

Turkmenistan

Article 9(2)

51

Ukraine

Article 9(2)

52

United Arab Emirates

Article 9(2)

53

United Kingdom

Article 9(2)

54

United States

Article 9(2)

55

Uzbekistan

Article 9(2)