Section 8 in The Agreement between the Government of Republic of India and the Government of Republic of Belarus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes of income
8. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 5 applies.
