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July 8, 2019
Belarusian tax authorities to begin requesting transfer pricing documentation for 2018 as of 1 June 2019
The Law of the Republic of Belarus “On amendments and additions to certain laws of the Republic of Belarus” No. 159-3 of 30 December 2018 came into force on 1 January 2019.
The Law sets forth significant amendments to the Tax Code of the Republic of Belarus (the 2019 Tax Code) related to the transfer pricing rules.
Among others, beginning from 2019, Belarusian tax authorities are entitled to request transfer pricing documentation during tax audits but no earlier than 1 June of the year following the tax period during which the transaction is completed. Therefore, it is expected that tax authorities will start to request transfer pricing documentation for 2018 from taxpayers as of 1 June 2019.
Moreover, the 2019 Tax Code requires special forms of transfer pricing (TP) documentation to be prepared by taxpayers and provided to tax authorities. The forms are approved by Decree of the Ministry of Taxes and Duties dated 3 January 2019, No. 2 “On certain issues related to the calculation and payment of taxes (duties), other payments, control over the calculation and payment of which is carried out by the tax authorities,” and entered into force on 16 February 2019. Prior to 1 January 2019, TP reports could be provided to the tax authorities in any format, but they had to include all information required by the Tax Code. Therefore, in 2019, tax authorities will start requesting TP documentation prepared using special forms, as stipulated by the 2019 Tax Code.
Other significant amendments pertaining to the TP rules, which became effective in Belarus as of 1 January 2019 are as follows:
For more details regarding changes in Belarusian TP rules, see EY’s publication, Transfer pricing rules in Belarus: Overview of the Main Amendments in 2019.
1. Organisation for Economic Co-operation and Development.
For additional information with respect to this Alert, please contact the following:
Ernst & Young Valuation and Advisory LLC, Transfer Pricing and Operating Model Effectiveness, Moscow
Ernst & Young LLC, Transfer Pricing and Operating Model Effectiveness, Minsk