On March 13, 2024, Resolution of the Council of Ministers of the Republic of Belarus dated 03.07.2024 No. 164 “On Taxation Issues” was officially published, which introduced special tax rules in relation to entities from “unfriendly” states.

1) The tax rate on the income of foreign organizations that do not operate in Belarus through a permanent representative office, and whose location is an “unfriendly” state included in the list determined by Resolution of the Council of Ministers of the Republic of Belarus dated April 6, 2022 No. 209, has been increased to 25%.

The increased rate applies to dividends and income equivalent to them (the Tax Code, art. 189, 1.4).

The measure was introduced for the period from April 1, 2024 to December 31, 2026.

2) The implementation of the provisions of international agreements on the avoidance of double taxation in relation to the payment of dividends, income from debt claims and income from the alienation of property is suspended.

The moratorium applies to double taxation agreements concluded with the USA, France, Denmark, Poland, Sweden, Belgium, Lithuania, Latvia, the Netherlands, the Czech Republic, Bulgaria, Estonia, Romania, Cyprus, Switzerland, Slovakia, Austria, Hungary, Croatia, Northern Macedonia, Italy, Germany, Finland, Ireland, Slovenia, Spain and Great Britain.

The moratorium was introduced for the period from June 1, 2024 to December 31, 2026.