Georgia: Treaty analysis: Georgia-Belarus double tax treaty enters into force

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Georgia: Treaty analysis: Georgia-Belarus double tax treaty enters into force

Pushkaryova-Anna

Anna Pushkaryova

On April 23 2015 Georgia and Belarus signed an agreement on avoidance of double taxation, prevention of evasion of income and capital taxes (DTT). The DTT applies to profit tax, income tax and property tax in Georgia and the tax on income, tax on profits, income tax on individuals and tax on immovable property in Belarus.

Among other provisions, the DTT stipulates, in particular, the following:

  • The profits of a company resident in one state will be taxable in that state only, unless the company has a permanent establishment (PE) in the other state, in which case the profits of said company may be taxed in that other state if attributable to that PE. The DTT determines PE as, in particular, a building site or construction or installation project lasting more than 12 months. The treaty also contains a number of exceptions when an enterprise shall not be deemed to have a PE;

  • A withholding tax on dividends at the rate of 5% (in case of at least 25% participation in the company paying the dividends) and at the rate 10% in all other cases;

  • A withholding tax rate of 5% on interest;

  • A withholding tax rate of 5% on royalties;

  • Income derived by a resident of one state from immovable property (including income from agriculture or forestry) located in the other state may be taxed in that other state;

  • Gains realised by a resident of one state from the alienation of shares or other participation interests of which more than 50 % of the value is derived directly or indirectly from immovable property situated in the other state, may be taxed in that other state.

According to the DTT, double taxation will be eliminated by applying a deduction from the tax of the Georgian resident in amount of the tax paid in Belarus and vice versa.

The DTT was ratified by Georgia on June 12 2015 and by Belarus on November 10 2015. Per the treaty's provisions, it entered into force on November 24 2015 and is effective as of January 1 2016.

Anna Pushkaryova (anna.pushkaryova@eurofast.eu)

Eurofast Georgia

Tel: +995 595 100 517

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The US president has raised India’s tariff rate to 50% because of its importation of Russian oil; in other news, firms made key international tax partner hires
Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
Its features include a built-in AI assistant as well as expert insights and commentary from Deloitte specialists
AI is rapidly finding its way into tax advisory services. But how can AI be deployed responsibly, reliably, and in compliance with legal standards?
Specified taxpayers will have to apply a 19% VAT rate on services offered by third parties through their platforms; in other news, Donald Trump imposed 30% South African tariffs
A ‘quiet revolution’ in HMRC’s compliance strategy has caused Adam Craggs to rethink how to advise clients, he tells ITR
If the Reform leader becomes UK prime minister then he may follow the direction of the US in at least one significant way
Trump declared a new national emergency in issuing the order; in other news, Grant Thornton Germany is up for sale and the subject of interest from both its UK and US counterparts
The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR
Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts
Gift this article