Most readers land on a Belarus Double Tax Treaty cheat sheet looking for one thing: what rate applies to me? In 2026 the honest answer depends on which of three groups your country sits in, and only one of those groups gets a treaty rate at all.
If you’re in any of the 27 “unfriendly” states — every EU member, plus the UK, the US, Canada, Norway, Switzerland and a handful of others — the treaty dividend, interest, and capital-gains provisions are suspended through the end of 2026. Belarus’s domestic rates apply, including a 25% rate on dividends to corporate non-residents from those jurisdictions. If you’re in a country whose treaty is still operative (China, the UAE, Turkey, India, Vietnam, Russia, Kazakhstan, and others), reduced treaty rates apply when you can demonstrate beneficial ownership. If you’re in a country with no Belarus treaty at all, domestic rates apply with no relief.
Below: the domestic baseline, how treaties usually reduce it, the suspended-states picture, a cheat-sheet table for the most-asked active treaty partners, and what it actually takes to claim a treaty rate at filing time. Some of this overlaps with the operational picture for foreign subsidiaries paying dividends abroad — that’s the operational article; this one is the rates reference. Both ages affect both, and both pages should be checked before any action.
Belarus’s domestic non-resident withholding rates come from the Tax Code Special Part, with current figures also published on the tax authority’s Tax Code page. For 2026 the operative numbers for corporate non-residents are:
Non-resident individuals get dividends at 13%. The reinvestment incentives (6% and 0%) sometimes mentioned in Belarusian tax summaries are domestic provisions for Belarusian recipients and don’t reach foreign shareholders.
The 25% unfriendly-state rate is the number that matters most to the suspended-treaty group. Combined with treaty suspension, it means the worst-case dividend rate for an EU/UK/US/Canadian/Swiss/Norwegian corporate shareholder in a Belarusian company is 25% through end of 2026 — substantially above the rate most would have paid under their previously operative treaty.
Belarus has roughly 70 double tax treaties in force, none of them amended through the OECD’s Multilateral Instrument because Belarus has not signed the MLI. The treaty network covers most major investor jurisdictions in Europe, Asia, the Middle East and Africa, and the basic mechanics are consistent across treaties.
A typical Belarus treaty caps dividend rates at 5–15%, often with a lower sub-rate for substantial shareholdings (5% where the recipient owns at least 25% of the payer is common). Interest is usually capped at 0–10%, with 0% common for government and financial-institution lending. Royalties sit in the 5–15% range. Treaty rates are not self-executing. The recipient has to qualify as the beneficial owner of the income, present a current tax-residence certificate to the Belarusian payer, and survive the look-through approach Belarus applies — which we’ll come to.
Picture a finance director in Frankfurt sitting down to model the after-tax return on a Belarusian portfolio company her firm owns. She opens the Germany-Belarus Double Tax Treaty, locates what should be her dividend rate. It isn’t available. And it won’t be again until at least 31 December 2026, because Belarus suspended the dividend, interest, and capital-gains provisions of 27 treaties from 1 June 2024 under Council of Ministers Resolution No. 164. Germany is on the list, along with every other EU member state and a few outside the EU. The formal policy rationale is on pravo.by.
The UK and US have layered additional mechanisms on top of the Belarus-side suspension. The UK revoked its Double Tax Treaty with Belarus in full on its own side in 2025; the US suspended Article III(1)(g) of the inherited 1973 US-USSR convention as it applies to Belarus from 17 December 2024 through 31 December 2026 (IRS Announcement 2025-5). For the finance director’s purposes — and for anyone in any of these jurisdictions — it doesn’t really matter which mechanism is the immediate cause. The outcome is the same: Belarusian domestic rates apply, and any structure built specifically to access the treaty rate is currently dormant.
The IRS’s Belarus tax treaty documents page is the right reference for the US-side current status; for the Belarus-side and EU readers, the Belarusian tax authority maintains the operative list.
Below are typical withholding rates for six of the most-asked active Belarus treaty partners. Rates are summary figures and most treaties have sub-rates depending on conditions (ownership thresholds for the lower dividend tier, lender categories for the lower interest tier, royalty types). Always check the actual treaty text before relying on a specific number.
| China | 10% | 10% | 10% |
| UAE | 5% / 10% * | 5% | 5% / 10% * |
| Turkey | 10% / 15% * | 10% | 10% |
| India | 10% / 15% * | 10% | 15% |
| Vietnam | 15% | 10% | 15% |
| Kazakhstan | 10% / 15% * | 10% | 15% |
* Lower rate available subject to conditions specified in the treaty (typically a substantial-shareholding test for dividends; royalty type or industrial-equipment carve-outs for royalties).
The following groups of jurisdictions have either treaty provisions suspended by Belarus through Resolution No. 164, or full treaty suspensions on their own side, or both. For investors in any of these countries, Belarusian domestic rates apply — including the 25% rate on dividends to corporate recipients.
For investors in an active-treaty jurisdiction, claiming the treaty rate means clearing three hurdles. The recipient must be a tax resident of the treaty country, evidenced by a current residence certificate from that country’s tax authority, provided to the Belarusian payer in advance of the payment. The recipient must be the beneficial owner of the income — not a flow-through entity passing the income up a holding chain. And the structure has to survive the look-through approach Belarus applies, which examines whether the treaty country recipient has actual business substance there beyond receiving the dividend, interest, or royalty in question.
The most common failure modes: holding-company structure with no operating substance in the treaty country, residence certificate dated after the payment was made, recipient is a partnership or other flow-through entity, the only commercial purpose of the structure is treaty access. Counterparty verification of the recipient before any treaty rate is applied is a good habit, particularly for first-time payments.
The Belarusian payer is the tax agent. The recipient provides the residence certificate (with apostille or consular legalisation where required — see our note on legalisation of foreign documents) to the payer before the dividend, interest, or royalty payment is made. The payer can then apply the treaty rate at source rather than the domestic rate.
If the documentation arrives late and the domestic rate has been withheld, refund claims are available but slow. The faster route is getting the certificate and any supporting documents to the payer’s accounting team before payment, not after. For an LLC or HTP-resident company paying dividends abroad, set this up as a standing process rather than handling it case by case.
The mechanisms vary, but the answer for you doesn’t. If you’re a resident of any developed-market jurisdiction — every EU member state, the UK, the US, Canada, Norway, Switzerland, and several others — at least one suspension applies to your country, and they all produce the same result. Belarus suspended the dividend, interest, and capital-gains articles of 27 treaties under Resolution No. 164, running from 1 June 2024 through 31 December 2026. The UK separately revoked the UK-Belarus treaty in full in 2025. The US separately suspended Article III(1)(g) of its inherited 1973 US-USSR convention as it applies to Belarus, from 17 December 2024 through 31 December 2026 (IRS Announcement 2025-5). Whichever mechanism touches your case, Belarusian domestic rates apply — with a 25% dividend rate for corporate recipients of unfriendly-state jurisdictions.
When there’s no treaty in play, the rate depends on what you are and what you’re receiving. The top rate is 25% — that’s dividends to a corporate recipient in an unfriendly-state jurisdiction, applied from 1 April 2024 through 31 December 2026. Below that, regular corporate non-residents pay 15% on dividends, 10% on interest, 15% on royalties. Individual non-residents pay 13% on dividends. And there’s one configuration that beats most treaty rates anyway: if the Belarusian payer is a High-Tech Park resident, the dividend rate is 5% regardless of the recipient — usually better than any treaty would have delivered.
We did a fair amount of work in the years before 2024 with Cyprus and Netherlands holding structures, because those were the routes most foreign investors used to hold Belarusian assets. As of 1 June 2024, that route stopped delivering its tax outcome. Both jurisdictions are on the suspended-treaty list, and their treaty rates for dividends, interest, and capital gains aren’t available through to the end of 2026 at the earliest. Belarusian domestic rates apply instead. We tell clients holding old Cyprus or Dutch structures the same thing: the vehicle still exists on paper, but on Belarus-sourced payments it currently pays the same rate a non-treaty entity would pay.
In practice, the answer comes in layers, and only one of them is paperwork. The starting document is a current tax-residence certificate from the recipient’s home tax authority, dated before the payment goes out — without it, the treaty rate isn’t on the table. The harder layer is what Belarusian tax authorities look at after the certificate clears: whether the recipient actually does business in the treaty country, who makes its decisions, and why this particular income is flowing through this particular entity. Treaty claims fail at that second layer more often than at the first. Holding-company structures with no real operations rarely survive the look-through.
The 5% rate is a domestic Belarusian provision: where the company paying the dividend is an HTP resident, the withholding rate is 5% on payments to non-residents, regardless of any treaty. Where a treaty rate would be lower (which is rare), the treaty rate applies. In practice, the HTP 5% rate is usually the better outcome for foreign shareholders of HTP companies.
No. The 25% rate applies specifically to dividends paid to corporate non-residents from unfriendly states. Interest and royalty rates remain at the 10% and 15% domestic levels respectively, regardless of the recipient’s country — but for the 27 jurisdictions whose treaties are suspended, those domestic interest and royalty rates apply with no treaty reduction available.
Bilateral conventions are published on pravo.by once ratified. The Belarus tax authority’s portal lists the treaties currently in force. For the US side specifically, the IRS publishes the inherited US-USSR convention and current suspension notices on its Belarus tax treaty page. For other jurisdictions, the home-country tax authority typically publishes the same treaty in parallel.
This article gives the framework and the most-asked rates. The actual rate that will apply to your specific payment depends on the exact treaty (and any protocols), the precise structure of your recipient entity, and whether the suspension regime currently covers your jurisdiction. If you’re modelling a structure or about to make a payment, get in touch. We’ll match the rate to the structure, confirm the current treaty status, and tell you what documentation to put in place before the payment runs.
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