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Belarus Clarifies Beneficial Ownership for Tax Treaty Benefits

06 May 2022

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Approved Changes

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Belarus

The Belarus Ministry of Taxes and Duties has published Letter No. 4-2-15/00340 of 25 April 2022, which provides guidance to clarify the concept of beneficial ownership for the purpose of claiming treaty benefits (reduced withholding tax or exemption) on dividend, interest, and royalty income. The letter first explains the concept of an actual beneficial owner according to generally accepted international practices, including that a beneficial owner is the person that has direct or indirect participation in or control over a legal entity, or by other circumstances has the actual right to receive and dispose of the relevant income at its...