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Belarus: Overview of new transfer pricing rules

Belarus: Overview of new transfer pricing rules

A new version of the tax law introduced amendments to the transfer pricing rules, effective at the beginning of 2019.


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The new measures are the first changes made to the transfer pricing rules since 2016 (when measures moved the transfer pricing rules in Belarus closer to international standards but preserved a 20% acceptable deviation from market prices and rules about control over the foreign trade transactions of non-related parties and low thresholds for controlled transactions, among other items).

The 2019 amendments repealed the 20% deviation from market prices. Also, the 2019 changes affected the rules concerning:

  • The composition of and procedure for determining related parties
  • Controlled transactions
  • The thresholds (limits) on transaction amounts
  • Special aspects of how to apply different methods to determine market prices

In addition, the new transfer pricing rules provide:  

  • A duty of the tax authorities to apply the market price determination method set forth by a taxpayer in its transfer pricing documentation until application of this method has been demonstrated to be inappropriate
  • A requirement for “major taxpayers” to submit to the tax authorities their transfer pricing documentation, when requested, no earlier than 1 June of the year following the year in which the relevant controlled transaction took place
  • A duty to provide the transfer pricing documentation / economic rationale in accordance with the forms and processes established by the Ministry of Taxes and Levies of the Republic of Belarus 
  • An option of entering into pricing agreements with the tax authorities regarding the taxation of “major transactions”

Read a 2019 report prepared by the KPMG member firm in Belarus

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