Italy has suspended key tax treaty provisions with Belarus covering dividends, interest, and capital gains, implementing reciprocal countermeasures under new legislative powers that allow mirror suspensions when foreign jurisdictions take unilateral action.
Italy officially notified Belarus on 12 March 2026 of its decision to suspend specific provisions of their bilateral income and capital tax treaty from 2005. This decision was published in Italy’s Official Gazette (Gazzetta Ufficiale) No. 69 on 24 March 2026.
The suspension affects three key articles: Article 10 covering dividends, Article 11 addressing interest, and Article 13 concerning capital gains.
The suspension operates under Italy’s Legislative Decree No. 192, enacted on 18 December 2025. This decree establishes a reciprocal mechanism: when a foreign jurisdiction unilaterally suspends tax treaty provisions, Italy can implement countermeasures by suspending the same provisions under Italian law, effective from the identical date.
