The Belarus Ministry of Taxes and Duties released detailed guidance on the upcoming tax reforms for 2025.

The key changes include the following:

New limitations on the investment deduction

New investment deduction limitations have been established, which apply to assets with depreciation starting on or after 1 January 2025. However, non-profit entities, such as budget organisations, public and religious organisations, cannot apply the deduction. It also excludes fixed assets with a service life under five years. Additionally, the deduction is only allowed for buildings and structures if they are used for industrial or production purposes.

New rules for the taxation of transactions

New regulations have been introduced for the taxation of transactions involving digital “tokens”, including a 9% tax rate for High-Tech Park residents. These rules cover profits or losses from services related to creating, promoting, and consulting digital tokens, activities of crypto and exchange platform operators, mining activities, and the sale or transfer of digital tokens, including those generated through mining.

Tax for microfinance and telecom operators

A permanent 30% tax rate has been set for commercial microfinance organisations and for mobile telecommunications operators offering telecommunications services in Belarus.

Reduced dividend tax rates to end by 2028

The reduced income tax rates on dividends are repealed for companies that reinvest profits and don’t make distributions for three or five years, with the 6% rate ending in 2026 and the 0% rate ending in 2028.

Investment fund tax benefits extended until 2030

  • A reduced 6% withholding tax on income from a Belarus-based investment fund is extended until 1 January 2030, which covers three years from the fund’s first profit year.
  • The tax exemption for investment funds has been extended until 1 January 2030.

Withholding tax on non-resident shareholders

  • A 15% withholding tax applies to payments made to non-resident corporate shareholders of Belarusian companies during liquidation.
  • A 25% withholding tax applies to dividends and similar payments unless reduced by a tax treaty, and the recipient’s residence and ownership are confirmed.

Unified BYN 400,000 threshold for loan transfer pricing

A unified threshold of BYN 400,000 has been set for applying transfer pricing controls to loan transactions. This threshold applies to all taxpayers, including large taxpayers.

These measures will generally take effect from 1 January 2025.