The Czech Republic tax authorities issued a guidance, on 1 July 2024, clarifying the suspension of Articles 10 (dividends), 11 (interest), and 13 (capital gains) of the tax treaty agreement between the Czech Republic and Belarus.

The tax treaty between the two countries was aimed at the avoidance of double taxation and the prevention of fiscal evasion with respect to the 1966 Belarus—Czech Republic Income and Capital Tax Treaty agreement.

Following this announcement, the Czech tax administration provided a detailed explanation of the implications of suspending the implementation of selected articles of the Treaty with practical examples that are divided into two categories:

  • The perspective of a taxpayer paying taxable income under any of the affected articles of the Treaty to a Belarusian tax resident and;
  • The perspective of a taxpayer, a resident of the Czech Republic, receiving taxable income from sources in Belarus.