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14 june 2024

Taxes: relationship changed but retained

It should be reminded that according to the governmental Resolution No. 164 of 07.03.2024 from June 1, certain articles of tax treaties with 27 countries (including the USA, UK, EU countries) are not applicable. 

  1. The following articles are suspended: 1) Dividends, 2) Interest, 3) Income from property.
  2. Rates of 0-6-12-15%-25% will apply, depending on the type of income (Article 192 of the Tax Code (TC) and 25% for dividends under Resolution No. 164).
  3. "New" rates apply if the date of tax liability under Art. 191 TC is in the period from 01.06.2024 to 31.12.2026. Such date is related to the date on which the liability or payment is recognized in the accounting records.
  4. The general tax rate on dividends for foreign companies is 15%, often tax treaties provided for lower rates of 10% or 5% (Cyprus, Great Britain). An increased rate of 25% is set for dividends to companies from "unfriendly" countries.
  5. The rule on elimination of double taxation is still in force, Belarus provides exemption for taxes paid abroad.