Tax Moratorium on Transfer Pricing Control for Targeted Loans until 2027

On 3 August 2025, amendments were introduced into tax legislation regarding transfer pricing control (TPC) for targeted loans. From now on, the corporate income tax base for the periods 2025–2027 is not subject to adjustment in respect of targeted loans granted to Belarusian organisations at an interest rate below market level.

What is meant by a targeted loan?

This type of loan is intended to finance current (core income-generating) activities and investment activities (transactions involving fixed assets, intangible assets and long-term investments), with the exception of the allocation of funds for financial investments.

With which counterparties are targeted loans exempt from transfer pricing control?

Transactions related to targeted loans are exempt from TPC if they are granted to:

• related Belarusian organisations entitled to exemption from corporate income tax (residents of free economic zones, taxpayers applying special taxation regimes, residents of the High Technology Park, the China-Belarus Industrial Park “Great Stone”, etc.);
• related Belarusian organisations applying the general taxation regime and paying corporate income tax;
• independent Belarusian organisations applying special taxation regimes.

At the same time, it is important to note that the amounts of targeted loans are not included in the total value of transactions with a single counterparty, whereas ordinary loans are subject to TPC where the threshold of BYN 400,000 is exceeded.

Important nuance!

Although the amendments were introduced on 3 August 2025, adjustment of the corporate income tax base does not apply to loan agreements concluded both before and after this date, but only in respect of the period until the end of 2027. 

Author: Katsiaryna Sushko, Ihar Razduyeu.