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17 january 2025

Amendments in taxation 2025

Law of the Republic of Belarus dated December 13, 2024 No. 47-Z “On Amendments to Laws” introduced amendments to the Tax Code of the Republic of Belarus, some of which entered into force on January 1, 2025.

There are some of them:

  1. Income tax of foreign organizations

New objects of taxation with the rate of 15% have been introduced:

  • income of foreign organizations received during the distribution of assets of liquidated Belarusian organizations among stockholders (shareholders);
  • income from the performance of work, the provision of services to interdependent party.

Tax rates have been increased:

  • on income from the alienation of shares (units, stocks) in the charter capital of Belarusian organizationsfrom 12% to 15 %;  
  • on dividends and equivalent income from 15% to 25%.
  1. Income tax

The benefit has been revoked when a citizen sells shares (stocks) in the charter capital of Belarusian organizations owned by the tax payer for at least three years.

  1. Control of the compliance of transactions with market prices

The list of transactions subject to market price compliance control has been expanded.

Now the control will also be subject to the transactions with interdependent party, with a tax payer applying special taxation regimes on

• purchase and sale of shares/stocks in carter capitals;

• granting or receiving a loan.

The limit for such transactions with one counterparty in a calendar year is at least 400 000 Belarusian rubles (excluding VAT).

  1. Avoidance of double taxation

If the condition for applying an income tax benefit, including a reduced rate, in accordance with the provisions of a Double Taxation Treaty is that the actual owner receives income, then in addition to confirming the status of foreign residence, it will be necessary to provide proof of the status of the actual owner of income in accordance with the form established by the Ministry of Taxes and Duties. In the event of amendment of the address, bank details, organizational and legal form, recipients of income (payments), or other amendments affecting the criteria by which the status of the actual owner of income is determined, the submitted confirmation is terminated from the date of such amendments.