On Taxation of Residents from “Unfriendly” Countries

News, 13 March 2024
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On March 13, 2024, the Resolution of the Council of Ministers dated March 7, 2024 “On Taxation Issues” has been published.

The Resolution established as follows:

1. The rate on dividends and equal incomes payable to residents of so-called “unfriendly” countries has been established at 25% (current standard rate is 15%). The increased rate is valid from April 1, 2024 until December 31, 2026.

2. The enforcement of certain provisions of international treaties on avoidance of double taxation with “unfriendly” countries is suspended.

So, the provisions regulating payment of taxes on dividends, interest on loans and other debt obligations, income from alienation of property (including sale of shares, real estate property, etc.) are suspended.

According to the Resolution, the relevant provisions of international treaties on avoidance of double taxation (DTT) with 27 countries are suspended.

The provisions of DTT with “unfriendly” countries are suspended from June 1, 2024 until December 31, 2026.

The period of suspension may be reduced if circumstances that caused their application are eliminated, or at the proposal of the Ministry of Taxes and Duties of the Republic of Belarus.

Please note that “unfriendly” countries in Belarus include: the USA, Great Britain, member states of the European Union, Switzerland, Norway, Iceland, Liechtenstein, Albania, North Macedonia, Montenegro, Canada, Australia, and New Zealand.

3. The authorized state bodies have been assigned to develop feasibility of changing the rates of corporate profit tax, personal income tax, withholding tax of foreign organizations that do not operate in the Republic of Belarus through a permanent establishment, on dividends and equal incomes.

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