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5.4. Tax Base for Non-Resident Entities

Non-residents with a PE in Belarus are subject to tax much in the same way as a resident company. (refer section 8.2.1 for details on computation of taxable income of PE’s)

Non-residents without a PE are subject to a final withholding tax on the gross amount of various payment streams deemed to be sourced in Belarus. To claim tax treaty benefits, such non-resident entities must furnish a confirmation of their permanent residency to the withholding tax agent. Such confirmation must be provided before the accrual of the Belarusian sourced income. In case, of any delay (i.e., documents furnished post the accrual or commencement of withholding tax assessment), the withholding tax agent may deny the benefit of tax treaty rates, unless such documents are furnished before the deadline for payment of the corporate tax and filing of the corporate tax return.