Most of the amendments came into force on 1. January 2026. A number of specific provisions have been introduced, largely reflecting existing practice. At the same time, new provisions have been introduced into the regulations, including a significant expansion of the powers of the tax authorities. Below is a brief of the key changes.
1. Tax authorities are now entitled to impose temporary restrictions on taxpayers with outstanding liabilities identified during a taxaudit, even before a formal decision is issued based on the audit report. Such measures may include:
- a temporary ban on deregistration of vehicles;
- a prohibition on registration actions involving real estate;
- a temporary restriction on the alienation of a share in the authorised capital of an organisation.
The decision is sent both to the taxpayer and to the relevant authorities or organizations (e.g. traffic police, commercial entities). The restrictions may be lifted within three working days after the taxobligation has been fulfilled and penalties have been paid.
2. The possibility of appealing against the requirement to eliminate violations is excluded. Previously, demands (orders) were subject to appeal along with decisions and actions (omissions) of tax officials.
3. Additional on-site audits may now be conducted, including in the context of bankruptcy proceedings. In addition, taxauthorities will have the right to establish the absence of a legalentity at its place of state registration by drawing up an inspection report.
4. The conditions for conducting an audit beyond the five-year period include the availability of information about violations committed by the taxpayer during the period under review. As a reminder, the period subject to audit for tax matters is no more than five calendar years preceding the year in which the decision to conduct the audit was made, plus the current year. For other matters, the period is no more than three calendar years preceding the year in which the decision to conduct the audit was made, plus the current year.
5. The right to engage experts and specialists has been extended to desk audits, not only on-site audits.
6. Updated criteria for inclusion in the list of large taxpayers: revenue from sales of at least 306,700,000 rubles for the year preceding the year of approval of the list + one of the following criteria:
- the total amount of calculated taxes and fees exceeds 24,000,000 rubles;
- the difference between tax deductions and the amount of VAT on sales exceeds 24,000,000 rubles (clause 3 of Article 82 of the Tax Code, clause 32 of Article 2 of the Draft).
7. Taxes and penalties owed by individual entrepreneurs (hereinafter – IEs) may now be recovered by the tax authorities without dispute from funds held in bank accounts and from electronic money in the IE’s digital wallet. Decision of collection may not be issued in respect of certain types of accounts (correspondent, escrow, special accounts, etc.).
8. The standard of “simplified” expense accounting for IEs has been revised. It should be noted that IEs have the right to determine expenses based on a fixed rate of 20% of their total taxable income. It is planned that from 2026, IEs who are exclusively engaged in retail trade and/or transport activities will be able to deduct 30% of their income as expenses. If, in addition to these activities, an IEs begins to engage in other activities, they will lose their right to the increased rate from the relevant month.
9. The rule has been specified that when conducting a desk audit of foreign organisations providing electronic services to individuals in Belarus/selling goods remotely, the tax authority may request, among other things, criteria for determining the place of sale of services and information on payments through Belarusian banks. The full list of information requested in relation to such activities remains open.
10. The procedure for monitoring foreign taxpayers engaged in remote electronic sales of goods/provision of services in electronic form remains in force. The change concerns the introduction of a new obligation for the tax inspectorate to inform the taxpayer of the results of its consideration of the explanations provided. If a debt exceeding 3,000 base values is identified and the payer has received a notice of violation, then upon submission of documents and explanations, the tax inspectorate shall review them within 30 calendar days and inform the payer of the results. If necessary, an additional notice with the revised amount of the debt shall be sent. As before, if the debt is not repaid, Inspection of the Ministry of Taxes andvDuties in Minsk will send the information to the Ministry of Taxes and Dutiesafter the 90-day period has expired, and the Ministry of Taxes and Duties will decide to restrict access to the relevant internet resource.
11. Obligation to provide information.
From 1. January 2026:
- Belarusian organizations engaged in the electronic trading of goods of Belarusian companies and IEs, including sales of goods outside Belarus, are required to submit quarterly reports to the Ministry of Taxes and Duties. These reports must indicate sales turnover by country to which the goods are delivered to customers. The form, structure, and format of such reports will be approved by the Ministry of Taxes and Duties at a later date. Although this obligation was introduced earlier, it effectively takes effect in 2026 with minor adjustments.
From 1. January 2027:
- Hi-TechPark residents must report to the tax authorities on the opening and closing of verified accounts of individuals on their platforms, as well as transactions linked to such accounts, where the total transaction amount in the previous year exceeded 150,000 rubles (in Belarusian rubles or per foreign currency or electronic money).
- Banks and payment service providers will be required to report not only funds received by individuals from abroad, but also funds transferred by individuals to foreign recipients.
