On 29 April 2021, the Tax and Duties Ministry of the Republic of Belarus has issued Guidance Letter No. 4-2-15/00981 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs).

The Guidance clarifies that if a nonresident company performs work and (or) renders services on the territory of the Republic of Belarus exceeding 180 days continuously or cumulatively in any 12-month period beginning or ending in the relevant tax period, the company would be recognized as a PE.

The Guidance also clarifies registration of foreign organizations and specifics the submission of tax returns (calculations) and fulfillment of Value Added Tax (VAT) and Corporate Income Tax (CIT) obligations.

The provisions of the Guidance would changes in the Tax Code effective from 1 January 2021.