Starting from 24 April 2024, investors from certain countries* (Affected Shareholders) will face restrictions when trying to receive dividends from their Belarusian subsidiaries. The details of the new restrictions are set out in Resolution of the Council of Ministers No. 299 (available in Russian) dated 19 April 2024 “On Application of a Special Restrictive Measure” (the Resolution).

According to the Resolution, the restrictions on payment of dividends will comprise the following measures:

  • limitation of the maximum amount of dividends that may be freely paid to Affected Shareholders
  • requirement to obtain a permit from the local executive committee in order to pay dividends exceeding this limit
  • in case a permit is not granted, a requirement to transfer the excess amount of dividends to special accounts with Belarusian banks

Dividend allowance

The limitation on free payment of dividends to Affected Shareholders applies to amounts exceeding 80,000 basic units per calendar year, which is equivalent to BYN 3,200,0001 (as of the date of this publication, 1 basic unit is equal to BYN 40).

It means that, if the total amount of dividends paid to all Affected Shareholders during a calendar year is equal to or less than 80,000 basic units (or the equivalent of this amount in foreign currency), the dividends may be paid freely. However, all payments of dividends to Affected Shareholders in excess of the indicated threshold will only be possible subject to either (i) obtaining a permit; or (ii) transferring the excess to special bank accounts (see details below).

Furthermore, the Belarusian subsidiary is now obliged to inform the relevant local executive committee at its place of registration about the amount of dividends actually paid to Affected Shareholders by sending a special form stipulated by the Resolution within 10 calendar days of the date of paying the dividends.


The limitation on the amount of paid dividends does not apply if the Belarusian subsidiary obtains a permit for dividend payment from its local executive committee.

This permit should be granted on a request by the Belarusian subsidiary submitted in accordance with the procedure established by the Resolution, provided that the relevant Belarusian subsidiary complies with all of the following criteria:

1. the total amount of dividends (both already paid and planned for payment) in the current calendar year does not exceed 50% of the average amount of foreign direct investments on a net basis for the five years preceding the year in which the dividends should be paid (residents of the Belarus Hi-Tech Park may opt out of this requirement)

2. the total number of employees in the current year’s reporting period is not less than 70% compared to the same period during the previous year

3. absence of net loss for the previous year and the reporting period during the current year

4. absence of outstanding debt:

  • on payment of taxes, levies and other obligatory payments to the budget, as well as budget loans, borrowings from state funds and certain other payments stipulated by the Resolution
  • on salaries and other payments to employees
  • on loans granted by banks operating in the Republic of Belarus and the Development Bank of the Republic of Belarus Open Joint-Stock Company and on interest for their use

5. the average nominal salary of employees (i.e. before taxes and other dues paid for an employee) for the previous year and the reporting period of the current year is not less than:

  • the monthly minimum salary in Belarus, i.e. BYN 2,191 (as of the date of this publication, the minimum salary is BYN 626) multiplied by 3.5; or
  • the monthly minimum salary in Belarus, i.e. BYN 7,199, multiplied by 11.5 – for residents of the Belarus Hi-Tech Park who have decided not to apply Criterion 1 above.

In addition to submitting an application to the executive committee, the Belarusian subsidiary must also give consent for banks to provide its credit report for it to the executive committee so that the latter is able to verify compliance with the criteria described above.

The local executive committee, along with other state bodies, reviews the application within 30 calendar days. In case all the information provided is correct and all the criteria are met, the local executive committee issues a permit for dividend payment and returns to the Belarusian subsidiary the application with the relevant note.

Special bank accounts

If the local executive committee refuses to grant a permit for dividend payment to an Affected Shareholder, such a payment can only be made by transferring the dividends to a bank account with a special operating regime.

This kind of special account should be opened with a Belarusian bank in Belarusian rubles. Until 31 December 2025, funds credited to the special accounts may not be transferred to the accounts of the Affected Shareholder and can only be used for specific purposes. For example, the funds may be used for:

  • financing investment projects within the territory of the Republic of Belarus
  • prepaying debts on loans provided by certain banks
  • acquiring certain state securities
  • placing non-revocable bank deposits for a term of no less than one year in the bank where the special account has been opened

You can find further information regarding special bank accounts in our newsflash via the link. 

*The new restrictions will apply to the residents of the following countries:

  • Canada
  • Commonwealth of Australia
  • EU states
  • Kingdom of Norway
  • Montenegro
  • New Zealand
  • Principality of Liechtenstein
  • Republic of Albania
  • Republic of Iceland
  • Republic of North Macedonia
  • Swiss Confederation
  • United Kingdom of Great Britain and Northern Ireland
  • United States of America

1) Approx EUR 924,000, based on the exchange rate of the National Bank of the Republic of Belarus as of the date of this publication.