You’ve had a good year, your Belarusian company has profit to spare, and you’d like to take some of it home as a dividend. Simple enough — until you ask two questions that people tend to blur into one. How much tax comes off the top? And, increasingly, can you actually move the money out of the country at all?

For a foreign shareholder these are different problems with different answers, and the one that catches people out is usually the second. This guide takes them in turn: the headline rate, the surcharge for owners from “unfriendly” states, the treaty relief that used to soften the blow, the High-Tech Park discount — and the payment controls that can leave a perfectly legal dividend stuck in Minsk.

The headline rate: 15%, withheld at source

Start with the number most shareholders actually want. When a Belarusian company pays a dividend to a foreign company, it withholds tax at 15% — a rate that has been in place since the start of 2023. The mechanics are mercifully simple: the company is the tax agent, so it calculates and withholds the tax itself, on the date the decision to distribute profit is taken, and pays it over to the budget. As a foreign shareholder you generally file nothing; the money arrives already net of tax. The rates themselves live in the Tax Code. For a foreign individual rather than a company, the rate is 13%.

Keep the layer underneath in mind too. A dividend is paid out of profit the company has already paid profit tax on, so the 15% sits on top of that — which is why it pays to look at the whole chain, not just the withholding line, when you work out what an owner actually receives. Our accounting team can model the full picture for your company.

When the rate jumps to 25%: shareholders from “unfriendly” states

Here is where your home jurisdiction starts to matter. From 1 April 2024 through to the end of 2026, dividends paid to companies based in “unfriendly” states are taxed not at 15% but at 25%. The list is the now-familiar one — every EU member state, plus the UK, the US, Canada, Norway, Switzerland and others — and the surcharge sits alongside the wider measures Belarus has aimed at owners from those countries. If your holding company sits in any of them, plan around 25%, not 15%.

The treaty relief that used to help — and is now switched off

For years, the answer to a high domestic rate was a double tax treaty. Belarus has a broad treaty network, and the right one could cut the dividend rate well below the domestic figure — often to 10% or 5%, sometimes lower for a substantial holding. For unfriendly-state shareholders, that door is, for now, closed. Since 1 June 2024, Belarus has suspended the treaty provisions on dividends — along with interest and capital gains — for the same group of 27 unfriendly states, through to the end of 2026, so it simply applies its domestic rate with no treaty discount.

If you are in a country whose treaty has not been suspended, relief may still be available — but it is not automatic. You have to qualify as the beneficial owner of the income, and Belarus applies a “look-through” approach to treaty claims, so a letterbox holding company will not do the work. Check the specific treaty and the beneficial-ownership position before you count on a reduced rate.

HTP and the rate reducers (and one that won’t help you)

Two levers are worth knowing, and one trap to avoid. The genuine lever is the High-Tech Park: if the company paying the dividend is an HTP resident, the withholding rate drops to 5%. For a foreign owner of a Belarusian tech business that is a real difference, and it is one reason HTP residency is so central to structuring an IT company here.

The trap is the reinvestment incentive you may have read about — the 6% rate for profit left undistributed for three years, and 0% for five. It is real, but it was built for Belarusian-resident shareholders, not foreign ones, so as an overseas owner it generally will not reduce your rate. It is also on the way out: under the Tax Code the 6% rate is being abolished from 2026 and the 0% rate from 2028. In short, don’t build a foreign-shareholder plan around it.

The second hurdle: can you even get the money out?

Now the question that surprises people, and the one tax tables never mention. Tax is about how much comes off the top; this is about whether the rest can leave. For owners from unfriendly states, paying dividends abroad is itself restricted. Above a threshold set in base units, the payment needs permission from the local executive authorities, and the restrictions currently run to the end of 2026. On top of that, profit payable to unfriendly-state owners is routed through special accounts, and what you can do with the money sitting there is limited — broadly to reinvestment and long-term deposits inside Belarus — unless you obtain approval to do otherwise. It is worth lining all of this up with your bank early.

Put plainly: a foreign shareholder from an unfriendly state can face both a 25% tax and a real possibility that the after-tax balance cannot simply be wired home. That combination — not the headline rate on its own — is what makes dividend planning here a genuine exercise rather than a formality.

How it works in practice

Whether your subsidiary is an LLC or a joint-stock company, the withholding works the same way once profit is distributed. End to end, the sequence looks like this:

• The company decides to distribute profit, and the tax point falls on that date.
• The company, as tax agent, withholds the dividend tax — 15%, 25%, or 5% for an HTP payer — and pays it to the budget.
• Where the shareholder is from an unfriendly state and the amount crosses the threshold, permission to make the payment is obtained.
• The dividend is paid through a permitted channel, which for unfriendly-state owners means the special-account regime.
• Where a non-suspended treaty applies, the reduced rate is claimed, with beneficial-ownership support.

So what does your dividend actually net?

It comes down to where the receiving parent or shareholder sits:

• A shareholder in a non-suspended treaty country: closest to a normal outcome — the domestic 15%, potentially reduced by treaty if you clear the beneficial-ownership test.
• An unfriendly-state corporate shareholder: 25%, no treaty relief, plus the payment controls — model both the net figure and the route home before you distribute.
• An HTP company: the 5% rate changes the maths considerably, and is worth structuring for if you are in tech.
• A foreign individual: 13%, with the same treaty and payment questions as a company.

Know the rate — and the route home

With Belarusian dividends, the headline rate is only half the story. What a foreign shareholder actually keeps depends on the surcharge, the suspended treaty relief, the HTP position, and whether the money can be repatriated at all. Those pieces are very different for a treaty-country owner, an unfriendly-state owner, and a tech business in the HTP.If you want a clear read on what your dividend will be taxed at and whether you can move it out, get in touch. We advise foreign owners in English, and we’ll work through the rate and the payment route for your specific situation.