On 10 March 2023, the Ministry of Taxes and Duties of Belarus issued Guidance Letter No. No.4-2-21/00759 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs). The updated guidance letter replaces the previous Guidance Letter No. 4-2-15/00981 of 29 April 2021, and effects from 1 January 2023.
The guidance letter covers several topics, including the definition of a PE of a foreign organization, tax obligations related to their activities in Belarus, registration and deregistration procedures with tax authorities, and the types of taxes that foreign organizations with a PE may be required to pay. The Ministry of Taxation and Duties also explained tax control measures that apply to such companies, including VAT and income tax. Furthermore, the document addressed the specifics of filing tax returns and fulfilling tax obligations for foreign organizations, as well as the peculiarities of companies operating in Belarus through multiple Permanent Establishments.