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Tax Treaties: United States And Belarus

Quick Summary.  The Republic of Belarus is an Eastern European country bordering Russia, the Ukraine, Poland, Lithuania and Latvia.  Following the fall of the USSR, Belarus attained the status of an independent country in 1991.  It is comprised of six provinces, with its capital in Minsk.

In 2019, Belarus implemented comprehensive tax reform, including changes with respect to “business purpose” taxation standards, as well as transfer-pricing and thin-capitalization rules.  Current transfer-pricing rules bring Belarusian framework closer to the OECD’s framework.

Belarus imposes a profits tax on corporations.  Resident companies are subject to tax on their worldwide income.  Non-resident companies are subject to tax on Belarus-sourced income that is derived through a permanent establishment.  Certain other non-resident company income is subject to withholding tax.

Recent tax reform measures specifically combat “resident of nowhere” status individuals.  Belarus taxes residents on worldwide income; non-residents are subject to tax on Belarus-sourced income.

Belarus is a member of the United Nations (UN) and the Commonwealth of Independent States (CIS), as well as the Eurasian Economic Union (EAEU).

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