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DTC agreement between Brunei Darussalam and Oman

DTC agreement between Brunei Darussalam and Oman

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Published by: eoiportal on May 04, 2011
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02/01/2013

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SULIT/CON
FIU.t.N
llAL
AGREEMENT
BETWEEN
THE
GOVERNMENT
OF
HIS
MAJESTY
THE
SULTAN AND YANG
DI-
PERTUAN OFBRUNEIDARUSSALAMAND
THE
GOVERNMENTOF
THE
SULTANATE OF
OMAN
FOR
THE
AVOIDANCE OFDOUBLE
TAXATION
AND
THE
PREVENTION
OF
FISCAL
EVASION
WITH
RESPECT
TO
TAXES
ON
INCOME
The Government
of
His
Majesty the Sultan
and
Yang
Dl-Pertuan
of
BruneiDarussalam
and
the Government
of
the Sultanate
of
Oman,
Desiring
to
conclude
an
Agreement
for
the Avoidance
of
Double Taxation
and
the Prevention of Fiscal
Evasion
with respect to
Taxes
on
Income,
Have
agreed
as
follows:
 
SULIT
ICONFIDENTIAL
Article 1
PERSONS
COVERED
This Agreement shall apply to
persons
who are residents
of
one
or both
of
theContracting States.
2
..
 
SULIT
CONFIDENTIAL
Article
2
TAXES
COVERED
1. This Agreement shall apply
to
taxes
on
income imposed
on
behalf
of
aContracting State irrespective
of
the manner in which they are levied.2. There shall
be
regarded
as
taxes
on
income all taxes imposed
on
total
income, or
on
elements
of
income, including taxes
on
gains from thealienation
of
movable or immovable property, taxes
on
the
total
amounts
of
wages or salaries paid
by
enterprises,
as
well
as
taxes
on
capitalappreciation.3. The existing taxes
to
which this Agreement shall apply are in particular:
a)
in the
case
of
Brunei Darussalam:(i) income tax imposed under Income Tax Act (Chapter 35);
and
(il)
petroleum profits tax imposedunder Income Tax (Petroleum)Act (Chapter 119);(hereinafter referred
to
as
"Brunei Darussalam
tax");
b) in
the
case
of
the
Sultanate
of
Oman:
(i) the company income tax imposed under Royal Decree
No.
47/1981
as
amended; and(ii) the
profit
tax
on
establishments imposed under Royal Decree
No.
77/1989
as
amended;(hereinafter referred
to
as
"Omani
tax").
4. This Agreement shall apply also
to
any identical or substantially similartaxes
that
are imposed
after
the date of signature
of
this Agreement inaddition to, or in place of, the existing taxes. The competent authorities
of
the Contracting States shall
notify
each
other
of
any significantchanges
that
have
been made in
their
respective taxation laws within areasonable period
of
time
after
such
changes.
3

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