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Belarus: New restrictions on dividends for businesses from “unfriendly countries”

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​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​published on 15 August 2025 | reading time approx. 2 minutes.


On 23 July 2025 the Resolution of the Council of Ministers of the Republic of Belarus No. 395 dated 21 July 2025 (hereinafter – “Resolution No. 395”) was issued and came into force on 24 July 2025. Resolution No. 395 tightened the restrictive measures on the procedure for Belarusian companies to pay dividends to shareholders from "unfriendly countries". 


The “unfriendly countries” comprise the ones as follows: ​

  • EU member states
  • USA
  • UK
  • Switzerland
  • Norway
  • Liechtenstein
  • Canada
  • New Zealan
  • Albania
  • Iceland
  • Montenegro
  • North Macedonia
  • Australia


As previously, restrictions include the obligation of a Belarusian company to obtain a single-use permit (hereinafter – the “Permit”) to be issued by a regional (Minsk City) executive committee in order to pay dividends to its shareholders from “unfriendly countries” (hereinafter – “Foreign shareholders”).
 
In contrast to the previous practice, from 24 July 2025, the restrictive measures apply to dividend payments to Foreign shareholders regardless of the amount of dividends.
  
According to Resolution No. 395 the amount of dividends due to the Foreign shareholder will determine only which criteria the Belarusian company must meet in order to obtain the Permit.
 

Criteria for obtaining the Permit​ (* the amount of dividends after tax withholding)​

Dividends of up to 20,000 basic units (Up to BYN 840,000 or approximately 243,000 euros)
Dividends exceeding 20,000 basic units (Exceeding BYN 840,000 or approximately 243,000 euros)​
  1. The headcount during the reporting period of the current year is at least 70 per cent of the level recorded during the same period last year
  2. ​No outstanding debts related to loans granted by Belarusian banks
  3. ​No outstanding debts related to taxes and other mandatory duties as well as payments due to the budget
  4. No outstanding debts related to salary payments
  5. No outstanding enforcement proceedings
  6. State authorities have no information about the Belarusian company that could prevent issuance of the Permit
  1. All the criteria specified in the left column of this table​
  2. The total amount of dividends in the current year does not exceed 50 per cent of the average volume of foreign direct investments into the Belarusian company over the previous 5 years. This criterion does not apply to Belarusian companies that are residents of the Hi-Tech Park (hereinafter – the “HTP”) if such companies meet criterion No. 4 below​
  3. Belarusian company did not incur any net losses during the previous year or during the current reporting period
  4. The nominal average monthly salary for the previous year and the current reporting period is at least 3.5 times the statutory minimum wage (as of today BYN 2,541 or ca. 736 euros)
 
Exception to this criterion applies to Belarusian companies that are residents of the HTP. For such companies the nominal average monthly salary for the previous year and the current reporting period must be at least 11.5 times the statutory minimum wage (as of today BYN 8,349 or ca. 2,420 euros), if criterion No. 2 is not applicable.
 
The aforementioned criteria for obtaining the Permit must be met by the Belarusian company collectively.
 
The processing time for the application for obtaining the Permit is 30 business days (as opposed to the previous 30 calendar days). In case of refusal to issue the Permit dividends are to be paid into a special account of the Foreign Shareholder in Belarus, which can only be used for limited purposes.
 
As previously, Belarusian companies are required to notify the regional (Minsk City) executive committee within 10 calendar days from the date of payment of dividends to Foreign shareholders.
 
Please note that the validity period of restrictions established by Resolution No. 395 has been extended to 31 December 2026.
 
Therefore, according to Resolution No. 395 dividends may only be paid to Foreign shareholders in any amount upon the receipt of the Permit.

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