The Belarus Ministry of Taxes and Duties has published Letter No. 4-2-21/01461 of 18 April 2025 on taxing foreign organisations operating in Belarus through a permanent establishment. The letter replaces Letter No. 4-2-21/00850 of 20 March 2024, and retroactively took effect starting 1 January 2025.
Letter No. 4-2-21/01461 provides guidance on permanent establishment concepts, PEs registration obligations, tax return, income tax and VAT requirements, and audits
One key update requires foreign organisations to restructure their permanent establishments (PEs) due to amendments under Law No. 312-Z, effective 19 November 2024. Foreign organisations operating in Belarus through a PE registered under the old rules must restructure or cease operations by this date.
To continue operating in Belarus, foreign organisations must either open a branch, create a legal entity, join an existing local entity, or cease activity by 19 May 2025.
The letter also outlines updated registration procedures for foreign organisations establishing a branch, along with guidelines on managing tax filings for these branches.
