Belarus Tax Treaty
Belarus – US Tax Treaty Quick Summary. The Republic of Belarus is an Eastern European country bordering Russia, the Ukraine, Poland, Lithuania and Latvia. Following the fall of the USSR, Belarus attained the status of an independent country in 1991. It is comprised of six provinces, with its capital in Minsk.
In 2019, Belarus implemented comprehensive tax reform, including changes with respect to “business purpose” taxation standards, as well as transfer-pricing and thin-capitalization rules. Current transfer-pricing rules bring Belarusian framework closer to the OECD’s framework.
Belarus imposes a profits tax on corporations. Resident companies are subject to tax on their worldwide income. Non-resident companies are subject to tax on Belarus-sourced income that is derived through a permanent establishment. Certain other non-resident company income is subject to withholding tax.
Recent tax reform measures specifically combat “resident of nowhere” status individuals. Belarus taxes residents on worldwide income; non-residents are subject to tax on Belarus-sourced income.
Belarus is a member of the United Nations (UN) and the Commonwealth of Independent States (CIS), as well as the Eurasian Economic Union (EAEU).
Income Tax Treaty between the United States and Belarus
Currency. Belarusian ruble (BYN).
Common Legal Entities. Joint stock company (public/private), limited liability company, representative office, permanent establishment of a foreign company.
Tax Authorities. Ministry of Taxes and Duties.
Tax Treaties. Belarus is a party to 70 tax treaties. It has not expressed any intent to sign the OECD MLI.
Corporate Income Tax Rate. 18% / 25%.
Individual Tax Rate. 9% (certain employees in IT and other technology industries referred to as HTP) / 13% (all others).
Corporate Capital Gains Tax Rate. No preferential treatment.
Individual Capital Gains Tax Rate. No preferential treatment.
Residence. A company is considered a tax resident if it is registered as a legal entity in Belarus. An individual is a resident of Belarus if he or she is physically present in the country for more than 183 days in a calendar year.
Dividends. 0% / 6% /12% (company residents) / 0% / 6% / 9% / 13% (individual nonresidents) / 5% / 12% (company nonresidents) / 9% / 13% (individual nonresidents).
Interest. 0% (company residents) / 13% (individual resident) / 0% / 10% (company nonresidents) / 13% (individual nonresidents).
Royalties. 0% (company residents) / 13% (individual resident) / 0% / 15% (company nonresidents) / 13% (individual nonresidents).
Transfer Pricing. Certain transactions may be subject to transfer pricing rules including real estate, cross-border, and domestic transactions. Tax authorities can apply the comparable uncontrolled price method, resale price method, cost plus method, transactional net margin method, and profit split method.
CFC Rules. No.
Hybrid Treatment. No.
Inheritance/estate tax. No.
Other. Entities can be subject to an environmental tax.
Tax Treaty Network – International Tax Attorneys
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