Belarus Tax Treaty

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Belarus Tax Treaty

Belarus International Tax Compliance Rules

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

Treaty.  Convention between the United States of America and the Union of Soviet Socialist Republics on Matters of Taxation

Currency.  Belarusian ruble (BYN).

Common Legal Entities.  Joint stock company (public/private), limited liability company, representative office, permanent establishment of a foreign company.

Tax AuthoritiesMinistry 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 Rate9% (certain employees in IT and other technology industries referred to as HTP) / 13% (all others).

Corporate Capital Gains Tax RateNo preferential treatment.

Individual Capital Gains Tax RateNo 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.

Withholding Tax.  

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 TreatmentNo.   

Inheritance/estate taxNo.

OtherEntities can be subject to an environmental tax. 

Tax Treaty Network – International Tax Attorneys

Our international tax expertise allows us to guide clients through tax planning and compliance so that they can focus on what matters most. At Freeman Law, our clients are engaged in an interconnected business environment that spans across the globe.  From supply chains to markets, cross-country taxation impacts every global business.

Do you have questions about Belarus’s Tax Treaties?  Schedule a free consultation with one of Freeman Laws International Tax Experts Today!