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,
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
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 ,
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 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 ,
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,
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 ,
 
 
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)