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Belarus - Raiffeisen Bank International AG

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12<br />

Excise tax takes the form of fixed amounts in <strong>Belarus</strong>ian rubles (BYR) charged per unit of goods. For<br />

instance, the excise tax on champagne and sparkling wine (1 litre) is BYR2,740 (€0.73), the tax on wine<br />

(1 litre) is €0.21 and the tax on a cigar is €0.57. When importing goods that attract excise tax, the importer<br />

must apply for and buy the excise tax stamp (proving payment of excise tax) and affix it to the product.<br />

Tax on the sale of car fuels<br />

<strong>Belarus</strong>ian companies must pay this tax when buying car fuels. The tax is levied at a rate of 10 per cent of<br />

the price of the gasoline or diesel. This tax is normally paid by the fuel wholesaler.<br />

Profit tax<br />

A profit tax of 24 per cent is imposed on company profits in <strong>Belarus</strong>. The profit tax is regulated in the Special<br />

Part of the Tax Code No. 71-3 of 29 December 2009. This tax must be paid by <strong>Belarus</strong>ian legal entities and<br />

foreign legal entities with a permanent establishment in <strong>Belarus</strong>, but the tax levied on a permanent establishment<br />

of a foreign company in <strong>Belarus</strong> is limited to the profits recorded by that permanent establishment.<br />

Under the double tax agreement between Austria and <strong>Belarus</strong> of 23 April 2002, the profits of Austrian companies<br />

operating in <strong>Belarus</strong> without setting up a permanent establishment are taxed in Austria. However,<br />

the profits that can be attributed to a permanent establishment of an Austrian company in <strong>Belarus</strong> (e.g. a<br />

subsidiary) are subject to <strong>Belarus</strong>ian profit taxation. The representative office of an Austria company is not<br />

subject to profit taxation in <strong>Belarus</strong> so long as the <strong>Belarus</strong>ian tax authorities have not deemed it to be a permanent<br />

establishment on the grounds of its activities. The double tax agreement also sets out special rules<br />

allowing the <strong>Belarus</strong>ian taxation at source of the profit distributions of <strong>Belarus</strong>ian companies with Austrian<br />

shareholders/members/partners (5 per cent if stake > 25 per cent: otherwise 15 per cent) as well as of profits<br />

from securities transactions (24 per cent) and transportation services (6 per cent).<br />

When rendering services in <strong>Belarus</strong>, one must take into account that the <strong>Belarus</strong>ian tax code specifies that,<br />

when a foreign company renders a service in <strong>Belarus</strong>, the revenues from that service will be taxed at source<br />

at a rate of 24 per cent of the value of the order. The recipient of the service must withhold the tax applying<br />

the reverse charge system. Installation and assembly services may be exempted.

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