An archive photo
MINSK, 2 April (BelTA) – At a meeting of the fourth session of the Council of the Republic of Belarus’ National Assembly of the eighth convocation, the bill “On ratification of the agreement between the Government of the Republic of Belarus and the Government of the Republic of the Union of Myanmar on the elimination of double taxation with respect to taxes on income and on the prevention of tax avoidance and evasion” was approved, BelTA has learned.
The agreement was signed on 28 November 2025 during the official visit of Belarusian President Aleksandr Lukashenko to Myanmar. The agreement is intended to delineate the tax jurisdiction of the two states and to establish a mechanism for avoiding double taxation on profits and income of businesses and individuals engaged in bilateral economic relations.
“The agreement is one of the fundamental documents that allows the two states to begin economic cooperation on a regular basis and under terms that are clear to both parties in the area of taxation. The key approach in the agreement for taxing organizations is that the right to fully tax profits and income belongs to the state where they are registered. At the same time, since organizations receive income from sources in another state without tax registration, the agreement grants that state the right to partially tax it,” Taxes and Duties Minister Dmitry Kiyko explained.
Firstly, this applies when organizations conduct business in another state through a permanent establishment, which includes a construction site or a place where services are provided. In such cases, the agreement requires the organization to pay tax on its profits in the state where the permanent establishment is situated, but only on those operations that pertain to that establishment.
Secondly, organizations are required to pay taxes in another state when they receive certain types of income from sources there, as defined in the agreement. These include income from maritime transport, use or sale of immovable property, dividends, debt obligations, royalties, management, technical or consulting fees, and proceeds from the sale of shares or stakes in the authorized capital of organizations. The agreement establishes tax rates for each of the specified types of income. The state that is the source of such payments has the right to withhold tax at rates not exceeding those stipulated in the agreement. The taxation of income of individuals has the same principle.
In cases where the agreement grants the state that is the source of profit or income the right to levy taxes, the state of tax residency – that is, the state of registration of the organization or the permanent residence of the citizen – provides a deduction from the amount of profit tax (income tax) equal to the amount of foreign tax withheld. Thus, double taxation is eliminated.
To ensure tax control over bilateral economic operations, the agreement grants the tax authorities of Belarus and Myanmar the opportunity to exchange information on tax matters. In order to create favorable economic conditions, the agreement provides for a more favorable taxation procedure for certain types of income compared to national legislation.
The agreement was signed on 28 November 2025 during the official visit of Belarusian President Aleksandr Lukashenko to Myanmar. The agreement is intended to delineate the tax jurisdiction of the two states and to establish a mechanism for avoiding double taxation on profits and income of businesses and individuals engaged in bilateral economic relations.
“The agreement is one of the fundamental documents that allows the two states to begin economic cooperation on a regular basis and under terms that are clear to both parties in the area of taxation. The key approach in the agreement for taxing organizations is that the right to fully tax profits and income belongs to the state where they are registered. At the same time, since organizations receive income from sources in another state without tax registration, the agreement grants that state the right to partially tax it,” Taxes and Duties Minister Dmitry Kiyko explained.
Secondly, organizations are required to pay taxes in another state when they receive certain types of income from sources there, as defined in the agreement. These include income from maritime transport, use or sale of immovable property, dividends, debt obligations, royalties, management, technical or consulting fees, and proceeds from the sale of shares or stakes in the authorized capital of organizations. The agreement establishes tax rates for each of the specified types of income. The state that is the source of such payments has the right to withhold tax at rates not exceeding those stipulated in the agreement. The taxation of income of individuals has the same principle.
The state of permanent residence of a citizen (according to the generally accepted rule, the state of residence is the state where the citizen stays for more than 183 days in a calendar year) has the right to tax income in full.
In cases where the agreement grants the state that is the source of profit or income the right to levy taxes, the state of tax residency – that is, the state of registration of the organization or the permanent residence of the citizen – provides a deduction from the amount of profit tax (income tax) equal to the amount of foreign tax withheld. Thus, double taxation is eliminated.
To ensure tax control over bilateral economic operations, the agreement grants the tax authorities of Belarus and Myanmar the opportunity to exchange information on tax matters. In order to create favorable economic conditions, the agreement provides for a more favorable taxation procedure for certain types of income compared to national legislation.
“The conclusion of the agreement creates the legal framework necessary for the implementation of economic and investment projects on a bilateral basis and ensures a stable tax regime over a long period,” Dmitry Kiyko stated.
Photos by Vitaly Pivovarchik/BelTA
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