The Belarus Ministry of Taxes and Levies has recently issued guidance concerning withholding tax obligations and the application of relevant treaty benefits for fees paid to non-residents by Belarusian sellers for access to online sales platforms. In general, when Belarus sourced income derived by a non-resident is not attributed to a Belarusian PE, it is then subject to withholding tax, with the Belarusian payer required to withhold the tax due. This also applies where a Belarusian resident sells goods or services via an online platform and the non-resident operator collects a fee from the sales price before sending the sales...