Corporate - Income determination

Last reviewed - 15 June 2020

Inventory valuation

Under domestic accounting legislation, stock used in the production and included in the cost of produced goods may be generally valued by the following methods:

  • Cost of each unit.
  • Average cost.
  • First in first out (FIFO).

The inventory valuation method used for CIT purposes must be the same method established by the taxpayer’s accounting policy.

Capital gains

Capital gains from disposal of shares/stocks in a Belarusian entity by another Belarusian entity are taxed as part of the latter’s profits and are subject to an 18% tax. No tax exemptions are provided by the Tax Code for the taxation of capital gains.

Dividend income

Dividends distributed by a resident company to another resident company are subject to 12% CIT, which is withheld by a paying company. CIT preferential rates of 6% and 0% are applicable if the profits were not distributed between the shareholders (the residents of Belarus) within the previous three or five calendars years, respectively.

Dividends distributed by a foreign entity represent non-operating income of a receiving Belarus entity and are subject to 12% CIT payable by the receiving entity in Belarus, irrespective of the fact that the foreign entity has paid the WHT on dividends distributed.

Dividends received by venture companies are exempt from CIT.

Dividends received by taxpayers from Belarusian companies are exempt from CIT in the hands of such taxpayers since CIT on dividend income is withheld by a respective dividend-distributing entity.

Inter-company dividends

The Tax Code provides no special exemptions for taxation of inter-company dividends.

Interest income

Interest on most types of bonds, including state, municipal, bank, and corporate bonds (issued during the period from 1 April 2008 till 1 January 2015 and starting from 1 July 2015) is exempt from the Belarusian CIT under certain conditions provided for in the Tax Code.

CIT at the standard rate of 18% is charged on interest income derived by a Belarus entity from another resident company.

Interest income derived by a Belarus entity from a foreign entity represents non-operating income of a receiving Belarus entity and is subject to 18% CIT payable by the receiving entity in Belarus, irrespective of the fact that the foreign entity has paid the WHT on interest income. 

Royalty income

Income from sale of property rights by a Belarusian entity is subject to CIT at the standard rate of 18%.

Property rights to research findings that are registered in the state register of property rights to the research findings are exempt from CIT.

Other significant items

The following types of income are not regarded as non-operating income (do not effect CIT obligations for a taxpayer):

  • 'Target financing' received from the state or municipal authorities. The taxpayer is required to hold separate accounting records of income and expenses derived and incurred within 'target financing'.
  • Goods (works, services), material rights, and funds granted:
    • to the successors by a legal entity in case of its restructuring
    • as an inter-company transfer pursuant to corporate decision
    • to taxpayers engaged in crop production, animal husbandry, fish farming, and beekeeping, provided that this income is spent for the appropriate activities, or
    • as a foreign gratuitous aid on conditions stipulated by the President.

Foreign income

Foreign income of Belarusian resident legal entities is taxed, except for dividends, as ordinary business income at the standard 18% CIT rate. Dividends are taxed at a 12% CIT rate.

There are no provisions in the tax legislation that allow tax deferral with regard to foreign income.