Belarus

Corporate - Tax administration

Last reviewed - 15 June 2020

Taxable period

The taxable period for CIT is a calendar year. The taxable period for CIT withheld on dividends accrued by Belarusian companies is a month.

Tax returns

A CIT return shall be submitted on a quarterly basis, whether a company has taxable income or not, by the 20th day of the month following the reporting period. The CIT return for the fourth calendar quarter is submitted not later than 20 March of the year following the reporting year.

The above CIT reporting rule is also applicable on PEs of foreign companies as well as non-commercial representative offices.

CIT withheld on inter-company dividends must be reported by a tax withholding entity no later than the 20th day of the month following the month in which the dividends were accrued.

Calendar quarter is the tax period for WHT in regard to income generated from legal entities and individual entrepreneurs. Individuals (who are not registered as individual entrepreneurs) being WHT agents may choose the tax period to be either a calendar quarter or a calendar year.

Payment of tax

CIT must be paid on a quarterly basis on actual results of financial and economic activity for a quarter, no later than the 22nd day of the month following the expired reporting period. CIT payment for the fourth quarter of 2020 shall be made no later than 22 December 2020 in the amount of 2/3 of CIT calculated based on the CIT amount for the third quarter of 2020 with subsequent recalculation of the whole CIT for the 2020 year and calculation of CIT to be additionally paid or reduced no later than 22 March 2021. 

The above deadline shall also be followed by PEs of foreign entities.

CIT on inter-company dividends shall be paid no later than the 22nd day of the month following the month when dividends were paid.

WHT is to be calculated, withheld, and paid by a Belarusian company or a PE of a non-resident company no later than the 22nd day of the month following the quarter when the payment was made / the income accrued (which is the earlier, except for interest income where taxable moment is chosen by the tax agent).

Late payment interest

Since 1 January 2019, late payment interest is limited by the amount of taxes additionally charged as a result of the tax authorities' audit.

Tax audit process

Due to a reform, scheduled audits are replaced with random ones in 2018. Controlling activity is planned to be performed mostly as monitoring and explanatory process, providing various information, organising seminars, and round tables.

The period to be covered with the audit shall not exceed five years plus the period from current year to date.

Statute of limitations

Starting from 1 January 2018, a five-year statute of limitations is applied to tax charges in Belarus.

Generally, the statute of limitations for penalty due to failing to fulfil tax liability is either three years after the date when violation was committed or six months after the date when violation was exposed by tax authorities.

Topics of focus for tax authorities

Below are the main areas that the tax authorities usually monitor in Belarus:

  • 'Business purpose' concept.
  • Application of CIT incentives.
  • CIT treatment of overdue loans and recognition of accounts payable above the statute of limitations.
  • Proper justification of deductible marketing, consulting, and other similar costs for CIT purposes.
  • VAT deductions and relevant justification thereof.
  • Tax treatment of reorganisations, mergers, and spin-offs.
  • Tax treatment of related-party transactions.
  • Tax treatment of charitable and other similar donations.