On 31 August 2015, the Belarusian Ministry of Taxes and Duties issued guidance that clarifies the permanent residence requirement for claiming tax treaty benefits. According to the guidance, a non-resident with no permanent establishment in Belarus may only be eligible for a reduced rate of withholding under an applicable tax treaty if confirmation of permanent residency is provided to the withholding tax agent. If the confirmation is provided after the dates of the accrual of the Belarusian …