The Tax Administration published Information on the impacts of the suspension of certain provisions of the double taxation treaty with Russia, in which it presents its income taxation methodology following the suspension of performing certain provisions of the double taxation treaty with the Russian Federation. Simultaneously, the Ministry of Finance informed that Belarus also announced a suspension in the performance of three provisions of the double taxation treaty.
On 30 April 2024, the Tax Administration published on its website Information on the impacts of the suspension of certain provisions of the double taxation treaty with Russia. Simply put, the methodology states that 2023 income has to be reflected according to the period of its generation, and subsequently, the respective tax treatment is to be applied.
Further, on 14 May 2024, in its Financial Newsletter No. 4, the Ministry of Finance published the information that (based on the diplomatic note received) Belarus announced the suspension of provisions no. 10, 11 and 13 (dividends, interests, profit from the alienation of assets) of the double taxation treaty in the period from 1 June 2024 to 31 December 2026. The respective provisions will not be applied on the Czech side either. Although the Republic of Belarus did not explicitly suspend the performance of provisions no. 23 and 25 of the treaty in this context, the suspension of provisions no. 10, 11 and 13 of the treaty necessarily affects the possibility to perform provisions no. 23 and 25 (double taxation avoidance, mutual agreement procedure) in the respective period from 1 June 2024 to 31 December 2026 as well.
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