Recent Transfer Pricing Developments in Belarus: Taking Careful Steps towards Integration into European Tax Law

At the end of 2018, Belarus adopted large-scale amendments to its Tax Code. Among other matters, transfer pricing provisions were markedly rewritten and expanded. A new version of the Tax Code envisages a number of changes, including an updated list of related parties, revised criteria for determining controlled transactions, modified rules on transfer pricing methods and documentation, as well as the introduction of advance pricing agreements. All of these modifications manifest that Belarus monitors global developments in transfer pricing carefully and adopts, albeit slowly, international best practices in this sphere. The new rules, which came into force on 1 January 2019, apply to transactions performed on and after this date. It is expected that amendments will significantly change the Belarusian transfer pricing scene.