The Double Taxation Relief and International Tax Enforcement (Belarus) (Revocation) Order 2025
This Order, effective April 1st, 2025, revokes the 2018 Double Taxation Relief and International Tax Enforcement agreement between the UK and Belarus.
The revocation applies to income tax, capital gains tax, corporation tax, and comparable Belarusian taxes, impacting tax years 2025-26 onward for income tax and capital gains tax, and financial years beginning April 1st, 2025, onward for corporation tax.
The stated reason for the revocation is not detailed in the Order itself.
Arguments For
Geopolitical Considerations: Revoking the agreement aligns with the UK's broader response to the political situation in Belarus. The government may cite its commitment to international sanctions and human rights concerns as justification.
Revenue Protection: The revocation may be presented as a measure to protect UK tax revenue by eliminating potential loopholes or avoidance schemes previously accessible through the existing agreement. Evidence of past tax evasion or potential future risk could be cited.
Legal Compliance & International Coordination: The measure might be explained as complying with international standards or as an alignment with similar actions from other countries in relation to Belarusian sanctions.
Policy Consistency: The decision might be presented as a consistent application of a broader UK policy toward countries with significantly weakened or otherwise compromised rule of law.
Arguments Against
Economic Impact: Revocation could negatively affect UK businesses operating in or with Belarus, potentially hindering trade and investment. The potential loss of revenue by these businesses and consequent loss of UK tax receipts might be cited.
Investor Uncertainty: The decision could create uncertainty among foreign investors considering doing business with the UK, impacting international investment. Lack of transparency and forecasting difficulties presented by the decision might be cited.
Limited Effectiveness: While intended to exert diplomatic pressure, the removal of agreements may not have any significant effect on the political situation in Belarus. Evidence lacking to suggest strong causational impact might be cited.
Alternative Approaches: Diplomatic pressure and targeted sanctions as alternatives to a comprehensive agreement revocation would limit adverse economic impacts and might be cited as beneficial in several instances.
Citation 1.
This Order may be cited as the Double Taxation Relief and International Tax Enforcement (Belarus) (Revocation) Order 2025.
This section provides the official short title for the legal instrument.
It is the Double Taxation Relief and International Tax Enforcement (Belarus) (Revocation) Order 2025.
Effect 2.
This Order has effect—
(a)
for the tax year 2025-26, and each subsequent tax year, in relation to—
(i)
income tax,
(ii)
capital gains tax, and
(iii)
any taxes imposed by the law of the Republic of Belarus that are of a similar character to income tax or capital gains tax;
(b)
for the financial year beginning on 1st April 2025, and each subsequent financial year, in relation to—
(i)
corporation tax, and
(ii)
any taxes imposed by the law of the Republic of Belarus that are of a similar character to corporation tax;
(c)
on or after 1st April 2025 in relation to any other taxes.
This section specifies when the Order's effects take hold.
For income tax and capital gains tax (and similar Belarusian taxes), it's effective for the 2025-26 tax year and all subsequent years.
For corporation tax (and similar Belarusian taxes), it's effective from the financial year starting April 1st, 2025, and all future financial years.
Any other taxes are affected from April 1st, 2025 onwards.
Revocation 3.
The Double Taxation Relief and International Tax Enforcement (Belarus) Order 2018 is revoked.
This section states that the 2018 Double Taxation Relief and International Tax Enforcement (Belarus) Order is now void.
Explanatory Note (This note is not part of the Order)
This Order revokes The Double Taxation Relief and International Tax Enforcement (Belarus) Order 2018 (“the 2018 Order”). The 2018 Order gave effect to arrangements between the United Kingdom and the Republic of Belarus with a view to affording relief from double taxation.
Article 2 sets out the dates from which this order has effect. For income tax and capital gains tax, and any taxes imposed by the law of the Republic of Belarus that are of a similar character, it has effect for the tax year 2025-26 and each subsequent tax year. For corporation tax, and any taxes imposed by the law of the Republic of Belarus that are of a similar character, it has effect for the financial year beginning on 1st April 2025 and each subsequent financial year. For any other taxes it has effect on or after 1st April 2025.
Article 3 provides that the 2018 Order is revoked.
A Tax Information and Impact Note has not been produced for the Order as it relates to a double taxation agreement.
The explanatory note clarifies that the Order revokes the 2018 agreement designed to prevent double taxation between the UK and Belarus.
It reiterates the effective dates for different types of taxes detailed in Article 2 and confirms the revocation of the 2018 Order.
It also explains that a Tax Information and Impact Note is not needed for these types of double taxation agreements.