On 13 March, a decree of the Belarusian government was published raising the tax on dividends from 15% to 25% for foreign organizations meeting the two following criteria:

• They do not operate in Belarus via a permanent establishment;
• They are incorporated in a jurisdiction listed as an unfriendly state.

It should be noted that there is currently a special procedure in place for using the dividends of foreign companies incorporated in a country subject to special counter-measures introduced by the government of Belarus. As per this procedure, dividends may be used via a special account and solely for purposes determined by the regulator

This step is temporary and is introduced from 1 April 2024 through 31 December 2026.

The decree is apparently intended to induce companies from unfriendly jurisdictions to start operating via permanent establishments or essentially operate under discriminatory conditions.

Please find more details in the memo.