Belarus ratifies agreement with Myanmar on avoiding double taxation
25.03.2026
MINSK (
BelTA) – On 24 March, Belarusian MPs ratified 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, BelTA has learned.
The agreement was signed on 28 November 2025 during the official visit of Belarusian President Aleksandr Lukashenko to the Republic of the Union of 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 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, Taxes and Duties Minister Dmitry Kiyko explained. However, since organizations receive income from sources in another state without tax registration, the agreement grants that state the right to partially tax it in two cases.
First, 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.
Second, 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 relevant articles of the agreement establish 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, Dmitry Kiyko noted. 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.
As with organizations, since a citizen may receive income from sources in another state or without tax residency there, that state can also tax it, but only partially. This right applies when an individual is paid for work in that state, or when individuals receive the same types of income as organizations.
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.
According to the minister, the conclusion of the agreement will create the legal necessary for the implementation of business projects on a basis and will ensure a stable tax regime over a long period.
The agreement was signed on 28 November 2025 during the official visit of Belarusian President Aleksandr Lukashenko to the Republic of the Union of 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 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, Taxes and Duties Minister Dmitry Kiyko explained. However, since organizations receive income from sources in another state without tax registration, the agreement grants that state the right to partially tax it in two cases.
First, 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.
Second, 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 relevant articles of the agreement establish 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, Dmitry Kiyko noted. 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.
As with organizations, since a citizen may receive income from sources in another state or without tax residency there, that state can also tax it, but only partially. This right applies when an individual is paid for work in that state, or when individuals receive the same types of income as organizations.
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.
According to the minister, the conclusion of the agreement will create the legal necessary for the implementation of business projects on a basis and will ensure a stable tax regime over a long period.