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12.4.4. APAs and Dispute Resolution Mechanisms

Advance Pricing Agreement (APA)

Effective from 1 January 2019, large taxpayers, as well as taxpayers having controlled transactions exceeding BYN 2 million may enter into an Advance Pricing Agreement (APA) with the tax authorities. The standard term of an APA is up to three years, although this may be extended by an additional two years. There are no rollback provisions.

Mutual Agreement Procedure (MAP)

Effective 1 January 2021, MAP provisions are introduced for resolving disputes if, in situations covered by a tax treaty, the actions of the tax authorities of one or both states result in double taxation.

The applicant may submit an application for MAP with relevant documents to the Ministry for Taxes and Duties of the Republic of Belarus (MTD). The MTD may send a request to the foreign tax authority to initiate MAP within 30 working days of receiving the documents.

MAP ends when an agreement is reached between the tax authorities or, when there is no agreement, within 3 years from the date on which the MAP request was submitted to the MTD.


If an adjustment is proposed by the tax authority, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/ assessments (see Sec. 13.7.)