LAW OF THE REPUBLIC OF BELARUS

of December 30, 2025 No. 127-Z

About change of the laws concerning tax legal relationship

Accepted by the House of Representatives on December 3, 2025

Approved by Council of the Republic on December 17, 2025

Article 1. Bring in article 7 of the Law of the Republic of Belarus of January 31, 1995 No. 3563-XII "About bases of the national social insurance" the following changes:

to exclude from word part one paragraph two of "the notaries performing notarial activities in notarial bureaus";

from the paragraph of the seventh of part two of the word", or applying the tax deduction on this tax" to exclude.

Article 2. Bring in the Tax code of the Republic of Belarus of December 19, 2002 the following changes:

1. In Item 2 of Article 13:

state subitem 2.19-2 in the following edition:

"2.19-2. the professional income – the income of physical persons – taxpayers on the professional income gained by them from implementation of independent professional activity, craft activity, activities for rendering services in the field of agroecotourism;";

in subitem 2.22 of the word", to distribution and placement" shall be replaced with words "and (or) to placement (distribution)".

2. From subitem 2.4 of Item 2 of Article 14 of the word of "The Belarusian notarial chamber" to exclude.

3. The ninth to state the paragraph to part two of Item 1 of Article 20 in the following edition:

"between the organization and the employee of this organization or physical persons, interdependent with such worker, specified in paragraph ten of this part;".

4. To add subitem 1.5 of Item 1 of Article 21 after the word "address" with the words "with the statement in written or electronic form".

5. In Article 22:

in Item 1:

in subitem 1.4.2 part four to replace the word "sixth" with the word "heel";

state subitem 1.10 in the following edition:

"1.10. represent to tax authority in the place of registration in the established form information on cash flow on the foreign bank accounts opened by the Belarusian organizations, except for correspondent accounts, for January-June – no later than July 31 of the current year and for July-December – no later than January 31 of the year following for reporting;";

the second item 4 to add part with the paragraph of the following content:

"confirmations that the foreign organization is the actual owner of the income (further – confirmation of the actual owner), in the form established by the Ministry of Taxes and Tax Collection.".

6." (The notary performing notarial activities in notarial bureau)" to exclude from the paragraph of the fifth subitem 2.1 of Item 2 of Article 26 of the word.

7. In Article 35:

in paragraph one of part one and part two of Item 31 "paid" to replace the word with the word "enlisted";

to add item 4 after part two with part of the following content:

"Privileges in the form of tax exemption, charges for the checked period in the amounts which are not reflected by the individual entrepreneur or the organization in tax declarations (calculations) for taxes (charges) which term of representation came before purpose of check for the taxation objects established and (or) corrected towards increase during check, application are not subject.";

in part three of Item 5 of the word "and third" to replace with the word "– the fourth".

8. In subitem 2.6 of Item 2 of Article 38 "agent" to replace the word with the word "aggregator".

9. In part three of Item 2 of Article 40:

add paragraph two with words "the foreign organizations";

after paragraph two to add part with the paragraph of the following content:

"to the income tax the Belarusian organizations in the presence of the amounts participating in case of determination of tax base on the income tax, and (or) tax amounts on profit, estimated for payment in the Republic of Belarus. The tax declaration (calculation) is submitted for the accounting period in which there were such amounts, and also for all subsequent accounting periods of this tax period;".

10. The fourth Item 9 of Article 42 to state part in the following edition:

"Without adoption of the decision by tax authority the debt of physical persons on single property payment, penalty fee on such payment is recognized the bad debt and is written off if for January 1 of calendar year the total debt on such payment, including penalty fee, does not exceed three Belarusian rubles irrespective of availability (absence) at such physical persons of property.".

11. To exclude Item 5 of Article 44.

12. To add part one of Item 1 of Article 47 with words ", the debt on penalty fee is recognized the bad debt and is written off without adoption of the decision by tax authority and irrespective of availability (absence) at such physical person of property".

13. In Item 1 of Article 48:

in part two of the word "paid by the organization, the individual entrepreneur or other physical person" to replace with the word of "enlisted";

in part three "paid" to replace the word with the word of "enlisted".

14. In paragraph one of part two and paragraph one of part three of Item 1 of Article 51 "paid" to replace the word with the word of "enlisted".

15. To state subitem 3.1 of Item 3 of Article 54 in the following edition:

"3.1. non-execution of the tax liability, failure to pay the penalty fee added by results of checks or in connection with submission of the tax declaration (calculation) with the made changes and (or) additions according to the notification of tax authority by results of carrying out the subsequent stage of cameral check – for the term specified in the pledge agreement of property, the guarantee agreement or the bank guarantee, but no more than six months;".

16. In Article 56:

in Item 2:

in part three of the subitem 2.1 of figure "2.4" to replace with figures "2.5";

state subitem 2.4 in the following edition:

"2.4. if the head of the commercial organization, the individual entrepreneur or other authorized in accordance with the established procedure to act on behalf of the commercial organization, the individual entrepreneur person have no data on the actual circumstances of implementation of business activity;";

add Item with subitem 2.5 of the following content:

"2.5. in case of establishment of the fact of absence of the legal entity of the Republic of Belarus by tax authority in the place of state registration.";

third Item 3 to state the paragraph in the following edition:

"the charitable accounts opened for collection, storage and use of money, including in foreign currency, arriving in the form of foreign free aid, the free (sponsor's) aid or donations;";

in Item 6:

to add paragraph two after figures "2.3" with figures ", 2.5";

the fourth after the word "checks" to add the paragraph with words ", carried out by tax authority,";

the fifth to state the paragraph in the following edition:

"receipts of information by tax authority from the head of the legal entity, the individual entrepreneur or other representative in accordance with the established procedure to act on behalf of the legal entity, the individual entrepreneur of person about the actual circumstances of implementation of business activity;".

17. In Item 1 of Article 61:

after part four to add Item with part of the following content:

"Tax collection, collection (duty), penalty fee from the physical person who is at the same time the individual entrepreneur can be made by tax authority according to this Code in indisputable procedure at the expense of the property of the individual entrepreneur specified in Article 62 of this Code.";

add Item with part of the following content:

"The decision of tax authority on tax collection, charges (duties), and also other obligatory payments in republican and local budgets, control of correctness of calculation by which timeliness and completeness of payment it is assigned to tax authorities is subject to cancellation in case of the direction by tax authority in court of the statement for tax collection, charges (duties), penalty fee from the physical person who is the citizen of the Republic of Belarus and living outside the Republic of Belarus.".

18. In Item 2 of Article 62:

third to state the paragraph in the following edition:

"the charitable accounts opened for collection, storage and use of money, including in foreign currency, arriving in the form of foreign free aid, the free (sponsor's) aid or donations;";

add Item with the paragraph of the following content:

"escrow accounts".

19. In item 4 of Article 64:

third to state the paragraph in the following edition:

"the charitable accounts opened for the payer's debtor for collection, storage and use of money, including in foreign currency, arriving in the form of foreign free aid, the free (sponsor's) aid or donations;";

add Item with the paragraph of the following content:

"escrow accounts".

20. In Article 65:

to add Item 3 after the word "realization" with the words "or other use";

state item 4 in the following edition:

"4. Expenses of tax and customs authorities on tax collection, collection (duty), are compensated by penalty fee for the account of property of the payer (the pledger, the guarantor) at his expense according to the procedure, established by the legislation, based on the decision of the head (his deputy) of the tax or customs authority accepted in the established form.".

21. In Article 66:

in Item 1:

in word part two "parts three and the fourth" shall be replaced with words "parts three";

the fourth to exclude part;

state Item 2 in the following edition:

"2. Offsetting of excessively paid amount of tax, collection (duty), penalty fee is made by tax authority independently in the following sequence:

on account of payment of this tax, collection (duty). Such offsetting is made with use of program and technical means no later than the working day following behind day when the tax authority knew of the amount of this tax which is subject to payment, collection (duty);

on account of execution of the tax liability on other taxes, charges (duties). Such offsetting is made within three working days from the date of identification of the fact of availability at the payer of the unexecuted tax liability;

on account of payment of single property payment. Such offsetting is made in the presence of excessively paid amount of tax, collection (duty), penalty fee not earlier than before ten working days before payment due date of such payment;

on account of payment of penalty fee on this tax, penalty fee on other taxes. Such offsetting is made within three working days from the date of identification of the fact of availability at the payer of unpaid penalty fee;

on account of collection of cost, confiscation of the income, payment of the penalties applied (imposed) by courts or tax authorities by results of hearing of cases about administrative offenses, protocols on which making are constituted by officials of tax authorities (further in this Chapter, Articles 70, 137 and 292 of this Code – administrative punishments). Such offsetting is made within three working days from the date of identification of the fact of availability at the payer of unexecuted administrative punishment.

Excessively paid by the payer including liquidated (who stopped activities), the tax amount, collection established during conducting check of the other person using the bases of item 4 of Article 33 of this Code is subject to offsetting by monitoring body independently during conducting check in case of determination of the amounts of the tax liabilities shown to such other person irrespective of the expiration of the five-year period from the payment due dates of tax, collection established by the tax legislation. The procedure for carrying out such offsetting is established by the Ministry of Taxes and Tax Collection in coordination with the State Control Committee.";

in Item 3:

from the paragraph of third of part one the third offer to exclude;

from word part three", except for to exclude filing of application about carrying out offsetting of the tax amount which is excessively paid by the payer, collection established by results of check of the other person";

in paragraph three of item 4 of the word "and the fourth" shall be replaced with words "– the sixth parts one";

to state part one of Item 5 in the following edition:

"5. Return of excessively paid amount of tax, collection (duty), is made by penalty fee according to the statement of the payer in case of absence at the payer of the unexecuted tax liability, unpaid penalty fee and unexecuted administrative punishments.".

22. To state Item 9 of Article 69 in the following edition:

"9. Registration of the physical person who is not the individual entrepreneur is performed:

based on the data received by tax authority from the register of the population, other documents and (or) information on such payer and (or) about the taxation objects;

in case of the personal appeal of physical person to tax authority behind implementation of ministerial procedures or issue of the notice on assignment of accounting number of the payer.".

23. In Article 70:

in Item 1:

the paragraph one after the word "entrepreneurs" to add with words ", the other persons who are taxpayers according to the legislation of foreign state";

to state paragraph two of part two of subitem 1.1 in the following edition:

"the copy of the power of attorney confirming powers of the head of representation including powers on representation of interests of the foreign organization in the relations regulated by the tax legislation;";

from paragraphs two and third subitem 1 part two. 2, subitem 1 part two paragraph two. 3, subitem 1 part two paragraph two. Paragraphs two and third parts two of subitem 1.6 of the word "original and" to exclude 4,;

in subitem 1.5:

to state paragraph two of part two in the following edition:

"the copy of the power of attorney confirming powers of the head of branch including powers on representation of interests of the foreign organization in the relations regulated by the tax legislation;";

in part three to replace the word "sixth" with the word "heel";

in Item 2:

exclude part one;

in part five of the word "second or fourth" shall be replaced with words "first or third";

in part seven to replace the word "sixth" with the word "heel".

24. In Article 72:

in subitem 2.2 of Item 2:

from paragraphs two and the sixth the word "checks" to exclude;

after paragraph two to add the subitem with the paragraph of the following content:

"when holding the procedures applied in course of production on the case of insolvency or bankruptcy;";

to exclude the word "checks" from the paragraph of third;

and "or" to exclude craft activity from the paragraph of the fourth word of "the notary performing notarial activities in notarial bureau";

after the paragraph of the sixth to add the subitem with the paragraph of the following content:

"carried out in case of the termination in the territory of the Republic of Belarus of activities of branches of foreign legal entities;";

in Item 3:

in part one word "seventh" and "ten" to replace respectively with the word "ninth" and figures "20";

after part two to add Item with part of the following content:

"The checks specified in paragraph three of subitem 2.2 of Item 2 of this Article are not carried out when holding the procedures applied in course of production on the case of insolvency or bankruptcy of the organization or the individual entrepreneur at which is on analysis results of information which is available in tax authority there is no unexecuted tax liability or the expected amount of the unexecuted tax liabilities and (or) the amount of the difference declared to return between the amount of the tax deductions and total amount of the value added tax estimated on sales of goods (works, services), property rights constitutes less than 20 basic sizes.";

third to state part in the following edition:

"In the presence of the order of criminal prosecution authority on the brought criminal case or vessels on the cases which are in its production check in case of liquidation of the organizations or the termination of activities of individual entrepreneurs, when holding the procedures applied in course of production on the case of insolvency or bankruptcy of the organization or the individual entrepreneur is carried out without the circumstances specified in parts one and third this Item.".

25. In Article 73:

second and third item 4 to state parts in the following edition:

"At the foreign organization, the foreign individual entrepreneur, the other person who is the taxpayer according to the legislation of foreign state rendering services electronically for physical persons, the tax authority has the right to request information on the criteria used for determination of the place of realization, confirmatory that the place of rendering of services the territory of the Republic of Belarus, the amount of revenue received from rendering services electronically, information on the payments received from buyers of services of the Republic of Belarus from the accounts opened in banks with the location in the Republic of Belarus and also other information relating to rendering such services electronically is recognized.

At the foreign organization, the foreign individual entrepreneur, the other person who is the taxpayer according to the legislation of foreign state performing electronic remote sales of goods, the tax authority has the right to request information, confirmatory that the place of sales of goods in case of electronic remote sales of goods the territory of the Republic of Belarus, the amount of revenue received from electronic remote sales of goods, information on the payments received from buyers of goods of the Republic of Belarus from the accounts opened in banks with the location in the Republic of Belarus and also other information relating to sale of such goods is recognized.";

state Item 101 in the following edition:

"101. Additional cameral inspection is carried out:

for confirmation of justification of the arguments stated in objections under the act of cameral check;

for confirmation of justification of the arguments stated in the claim to the decision under the act of cameral check;

when obtaining after decision under the act of cameral verification of information from tax authorities of other states, courts, state bodies and other organizations, including on the inquiries sent to their address.

The statement of additional cameral check shall be drawn up no later than two months from the date of:

emergence of the bases specified in paragraphs the second and fourth to part one of this Item;

decision makings about purpose of additional check following the results of consideration of the claim to the decision under the act of cameral check.".

26. In Article 731:

in Item 14:

in subitem 14.2 "performing" to replace the word with the word "performing";

in part four of subitem 14.5 of the word "or the individual entrepreneur, performing" to replace with the word", performing";

in Item 20:

the second to state part in the following edition:

"The statement of additional check shall be drawn up no later than three months from the date of emergence of the circumstances specified in part one of this Item, and in case of the direction when conducting additional verification of the requirement according to part seven of this Item – no later than three months from the date of, the expiration following behind day established for submission of explanations about sources of the income according to such requirement.";

add Item with part of the following content:

"If when conducting additional check by results of creation of the specified calculation excess of expenses over the income is established, the requirement about submission of explanations about sources of the income according to the procedure, stipulated in Item the 10th this Article goes to physical person concerning such expenses if earlier when conducting check, including additional, concerning such expenses the requirement did not go.".

27. In Article 74:

in Item 3:

in paragraphs five, the seventh and eighth the word "fourth" to replace parts one with the word "fifth";

in part two of the word "has the right to bring" to replace with the word "brings";

state item 4 in the following edition:

"4. Check concerning the checked subject on the same question for the same period is not allowed.

The requirement containing in part one of this Item does not extend to the inspections which are carried out according to orders of the President of the Republic of Belarus, Council of Ministers of the Republic of Belarus, the Chairman of the State Control Committee, criminal prosecution authorities on the brought criminal cases, courts on the cases which are in their production, additional checks, checks regarding observance of procedure for calculation and the tax discharge on value added if the specified questions for the corresponding periods are checked within exit check for confirmation of justification of return of the amount of exceeding of the value added tax.

Regarding questions of observance of the tax legislation are performed for the period, not exceeding five calendar years preceding year in which the decision on purpose of check, and for the expired period of the current calendar year is in accordance with the established procedure made. In case of submission of the tax declaration (calculation) for the income tax with changes and (or) amendments according to which increases there (is) amount of the received loss in comparison with earlier provided tax declaration (calculation) for the income tax, or the tax declaration (calculation) for the value added tax with changes and (or) amendments according to which the tax deductions in comparison with earlier provided tax declaration (calculation) for the value added tax, for the period, the exceeding specified five-year period increase, is performed for the period for which the tax declaration (calculation) with changes and (or) amendments, and in the presence of information testimonial of committed violation of the law in this period is provided. Regarding other questions within competence of tax authorities the checked period is limited three calendar years preceding year of decision making about purpose of check and the expired period of the current calendar year.

The period determined by part three of this Item is not limited in carrying out cases:

checks according to orders of the President of the Republic of Belarus, Council of Ministers of the Republic of Belarus, the Chairman of the State Control Committee and his deputies;

checks according to orders of criminal prosecution authorities on the brought criminal cases;

checks according to orders of courts on the cases which are in their production;

additional check.";

in Item 5:

in parts one and the second to replace the word of "fourth" with the word of "third";

third after the word of "three" to add part with the word of "workers";

in Item 6:

to replace the word of "courts" with the word "courts";

"appointments and" to exclude words;

in Item 8:

to exclude from word part one paragraph two of "the notary performing notarial activities in notarial bureau," and ", not being the legal entity or the individual entrepreneur";

after part one to add Item with part of the following content:

"If the term of the appointed check is less maximum permissible, such term can be increased within the term specified in part one of this Item, according to the decision of the head (his deputy) of the tax authority performing, according to the procedure, established by part two of Item 3 of this Article.";

the second to add part with the words "and courts on the cases which are in their production";

part the fourth after words to "criminal case" to add with words "courts on the cases which are in their production,";

part third of Item 9 after words of "exit check" to add with words "over the terms, established by part one of Item 8 of this Article".

28. In Article 75:

in Item 2 part one the word of "subject" to replace with the word of "subject";

in part one of Item 3 of the word "the paragraph the second" shall be replaced with words "paragraphs second and third".

29. From parts two and third Item 5 of Article 76 of the word" (the notary performing notarial activities in notarial bureau)" to exclude.

30. From the name and part one of Item 1 of Article 77 to exclude the word "exit".

31. In Article 81:

in Item 5:

state part one in the following edition:

"5. The act (reference) of check within two working days from the date of his (her) signing by the official of tax authority performing is handed under list to the payer or his representative for signing. In the absence of possibility of delivery of the act (reference) of check to the payer or his representative under list the act (reference) of check goes for signing to the payer or his representative the registered mail with the notification on obtaining.";

the first offer of part two to state in the following edition:

"In case of refusal persons (one of persons) specified in Item 3 of this Article from signing of the act (reference) of check in case of his (her) delivery in it (in it) the corresponding mark becomes.";

third after the word of "three" to add part with the word of "workers";

state Item 8 in the following edition:

"8. The decision according to the inspection statement is handed under list or goes the registered mail with the notification on obtaining to the payer or his representative.

In case of absence of the payer or his representative in tax authority for receipt of the decision according to the inspection statement, or refusal of receipt of the specified document under list, or absence of the payer in the location (residence) specified in constituent documents (the certificate on state registration) and (or) to the last known tax authority in the decision according to the inspection statement the corresponding entry is made and it goes the registered mail with the notification on obtaining on the last known tax authority to the location (residence) of the payer or his representative. In this case the decision according to the inspection statement is considered the received payer after three working days from the date of such direction.".

32. In Item 3 of Article 82:

in paragraph one of figure "207 600 000" to replace with figures "306 700 000";

in paragraphs second and third to replace figures "16 200 000" with figures "24 000 000".

33. In Article 84-1:

in Item 2:

after part one to add Item with part of the following content:

"If the payer after the direction in its address of the notification provides to inspectorate of the Ministry of Taxes and Tax Collection for the city of Minsk documents, information and (or) explanations, inspection no later than thirty calendar days following behind day of their representation informs the payer on lack of the bases for adjustment of outstanding amount or in the presence of such bases withdraws earlier directed notification with the simultaneous direction to the payer of the notification with indication of the corrected outstanding amount if its size exceeds 3000 basic sizes.";

in part two:

after the word of "period" to add part with the words "if other term is not established by this Item";

add part with the offer of the following content: "If devyanostodnevny term expires during consideration of documents, information and (or) explanations according to part two of this Item, the specified term is prolonged before completion of the 30-days period established for their consideration.";

"repayment" to exclude the word from part three;

part the fourth after the words "articles", and "such violations" to add respectively with the words "or withdrawal of the notification without the direction instead of the notification with indication of the corrected outstanding amount" and "or withdrawal of such notification";

in Item 3 part one to replace the word "second" with the word of "third";

in item 4:

after the word of "violations" to add Item with the words "or withdrawal of the notification without the direction instead of the notification with indication of the corrected outstanding amount";

to replace the word of "fourth" with the word "heel";

to add part one of Item 5 with words ", or exceptions of the corresponding identifier of the specified list".

34. In Article 85:

in Item 6:

in part one:

the words "regional (the Minsk city) notarial chambers, the notaries performing notarial activities in notarial bureaus" to exclude;

shall be replaced with words the words "including" "and also";

in part two:

from the paragraph of the fourth word", notaries" and ", notarial" to exclude;

from the paragraph of the eighth word" to exclude the notaries performing notarial activities in notarial bureaus";

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