Ordinary and capital losses can be carried forward for 5 years (reduced from 10 years retroactively from 1 January 2022). Losses from operations with securities and sales of fixed assets may be carried forward and set off against profits from the same operations only. Any unreported losses, discovered subsequently during tax audits or any increase in losses during tax audits, are not allowed to be carried forward.

However, the following losses may not be carried forward by a company:

• Losses incurred as a result of activities outside Belarus, if the company is registered as a taxpayer in such foreign jurisdiction; or
• Losses incurred at the end of the tax period during which the company was entitled to claim the exemption from corporate tax i.e., tax holiday period covering several tax years (effective 2019).

As regards the second restriction on losses incurred during the tax holiday period, it is clarified by a 2021 Circular that the restriction does not apply to residents of Free Economic Zones (FEZs – see Sec. 10.1), which benefit from corporate tax exemptions. The corporate tax exemption for FEZ residents is not limited to a certain number of tax years and hence, FEZ residents may carry forward losses incurred in tax years 2019 to 2021 and later years according to the standard rules.