At a glance
- Belarus offers aggressive tax incentives via state-guaranteed investment contracts under Decree No. 10, including full VAT refunds on imported project equipment and reduced corporate income tax rates of 20–25% (justice.by).
- Sanctions risks remain elevated but diverging: the EU’s 19th sanctions package (October 2025) banned transactions with three major Belarusian banks effective December 2025, while the U.S. eased restrictions in March 2026 — delisting Belaruskali from the SDN list and authorising Belinvestbank transactions (EU Council; OFAC).
- EU tariffs on Belarusian fertilizers and agricultural goods follow a phased escalation schedule through 2028, reaching up to EUR 430 per tonne for combined fertilizers.
- “Investment migration” in Belarus means tax incentives and residency are separate tracks — Decree No. 10 does not confer immigration status, although a permanent residence pathway exists for investors meeting a minimum of 15,000 basic units (~USD 200,000).
Last updated 6 April 2026
Belarus investment migration sits at the crossroads of strong tax benefits and tightening sanctions risks. For investors weighing where to place capital — and possibly where to base teams — the question is whether state-backed incentives can offset a volatile external environment. This guide explains what’s on offer under Decree No. 10 and the 2024 Investment Law amendments, how EU and U.S. sanctions have evolved through early 2026, and what practical options exist for residency and banking.
Belarus investment overview: why investors are attracted
Belarus continues to court capital through state-guaranteed investment contracts that can deliver significant tax savings — most notably, full VAT refunds on imported equipment and goods integral to qualifying projects (justice.by). The 2024 amendments to the Investment Law introduced updated mechanisms for “investment agreements for major projects of national importance,” including five-year stabilisation clauses and special investment contracts with state repurchase obligations (UNCTAD).
However, geopolitics weighs heavily. The EU’s 19th sanctions package of October 2025 added 64 new listings (22 individuals and 42 entities) with expanded trade restrictions, while banning EU residents from all financial and business transactions with Alfa-Bank Belarus, Sberbank Belarus, and VTB Bank Belarus effective 2 December 2025 (EU Council). On the U.S. side, the trend has been toward selective easing: in November 2025, OFAC delisted Belavia, and on 26 March 2026, OFAC issued General License 14 for Belinvestbank, removed Belaruskali and Belarusian Potash Company from the SDN list, and rescinded Directive 1 under EO 14038 (OFAC).
| What attracts investors | What raises risk |
|---|---|
| Full VAT refunds on imported project equipment via Decree No. 10 contracts | EU 19th package (Oct 2025): 64 new sanctions listings, banking transaction bans |
| Corporate income tax of 20% (25% above BYN 25M threshold) | EU phased tariffs on fertilisers escalating to EUR 430/tonne by 2028 |
| Six free economic zones with preferential taxation | EO 14038 authorises U.S. secondary sanctions on non-U.S. persons |
| 2024 Investment Law: five-year stabilisation clause for major projects | SWIFT exclusions for Belarusian banks remain in force |
| U.S. easing: Belaruskali delisted, Belinvestbank GL issued (March 2026) | Compliance screening burdens and banking access friction |
State-guaranteed investment contracts (Decree No. 10)
Presidential Decree No. 10 of 6 August 2009 remains the operative legal basis for state-guaranteed investment contracts in Belarus. Under these contracts, the government can grant extensive incentives — including full refunds of VAT paid on imported equipment and goods used for the investment project — materially improving project IRRs by reducing capital costs (justice.by).
The January 2024 amendments to Belarus’s Investment Law created a parallel mechanism: “investment agreements for major projects of national importance.” These introduce additional protections including a five-year stabilisation clause (locking regulatory conditions for the investor) and special investment contracts with state repurchase obligations. Some elements previously under Decree No. 10 have shifted to decisions of the President or Council of Ministers under this updated framework.
Additional incentives under investment contracts
- Land acquisition without public tender for project implementation.
- Reduced or zero corporate income tax for specified periods.
- Exemptions on real estate and land tax tied to the project.
- Customs duty relief on imported capital goods.
- VAT refunds on imported equipment and goods integral to the project.
How to apply (practical sequence)
- Scoping and alignment: Define project scope, capex, and import needs. Ensure the proposal aligns with priority areas that may qualify for a state-guaranteed contract.
- Approach competent authority: Engage the designated Belarus authority (typically the Ministry of Economy) to present the investment proposal and begin the contract process.
- Negotiate terms: Finalise contract terms, including specific incentives (VAT refund, CIT reduction, land access) and implementation obligations.
- Execute and register: Conclude the state-guaranteed contract and comply with registration or notification steps required for incentives to take effect.
- Import and reclaim: Import qualifying equipment and goods for the project and claim VAT refunds as provided in the contract.
- Ongoing compliance: Maintain documentation and reporting to substantiate incentive use and satisfy audits.
Corporate tax rates and free economic zones
Belarus uses a tiered corporate income tax structure. The standard rate is 20% for profits below BYN 25,000,000, rising to 25% for profits above that threshold. Investment contracts and free economic zone (FEZ) regimes can reduce or eliminate CIT for specified periods, alongside exemptions on real estate tax, land tax, and customs duties.
Six free economic zones remain operational: Brest, Vitebsk, Gomel-Raton, Grodnoinvest, Minsk, and Mogilev. FEZ residents benefit from preferential taxation including reduced CIT, property and land tax exemptions, and customs advantages. The Great Stone Industrial Park — a China-Belarus special economic zone — continues as a major platform for industrial investment with its own preferential regime.
No new nationwide FEZs have been created in 2024–2026, although existing zones have seen periodic adjustments to their operating conditions.
Immigration and residency for investors
A critical distinction: Decree No. 10 and the updated Investment Law address tax and customs incentives for investment projects. They do not confer immigration status, visas, or residence permits. Investors must treat immigration and investment as entirely separate tracks.
That said, Belarus does offer pathways for investor-based residency:
- Permanent residence via investment: The Law on Legal Status of Foreign Citizens allows residence permits for qualifying investments meeting a minimum of 15,000 basic units (roughly USD 200,000). Physical presence is required for at least half of each year. Naturalisation eligibility follows after seven years.
- Temporary residence via company establishment: Investors who establish or operate a company in Belarus can obtain temporary residence permits, which are renewable and grant lawful stay during the business activity.
- Real estate route: Property purchases (from approximately EUR 150,000) can serve as a basis for residency, though this is not automatic and requires additional documentation.
- Standard work permits and business visas: Available for foreign nationals managing or working in their Belarus-based operations. Belarus does not have a distinct “investor visa” category.
Belarus is also an EAEU member (alongside Russia, Kazakhstan, Kyrgyzstan, and Armenia), which means investors who establish presence in Belarus gain access to the broader EAEU market of approximately 180 million people with reduced trade barriers.
Does Belarus have a citizenship-by-investment programme?
No. As of April 2026, Belarus does not have a formal citizenship-by-investment (CBI) programme. However, Belarusian lawmakers have been advancing a proposal to simplify citizenship for foreign investors — an expert council has considered a draft law to amend the citizenship legislation. This remains under legislative consideration with no confirmed adoption date. Any future programme would likely require qualifying investment thresholds and be subject to additional vetting.
Sanctions landscape in 2026
The EU and U.S. sanctions regimes against Belarus are diverging significantly in early 2026. Understanding both is essential for any investment decision.
EU sanctions: tightening
The EU’s 19th sanctions package, adopted on 23 October 2025 (Council Regulation (EU) 2025/2041), remains the most recent formally adopted package with Belarus-related measures. Key provisions include:
- 64 new asset-freeze listings targeting individuals and entities in Belarus’s military-industrial complex, logistics, crypto, energy, and circumvention networks.
- Full ban on EU residents conducting financial and business transactions with Alfa-Bank Belarus, Sberbank Belarus, and VTB Bank Belarus, effective 2 December 2025.
- Expanded export bans on goods facilitating Belarusian military systems, including electronic components, chemicals, metals, alloys, and broader industrial goods (tyres, construction materials, grinding stones).
- Extension of crypto-asset restrictions to additional Belarusian entities.
A 20th package has been discussed but has not been formally adopted as of April 2026, reportedly delayed by member-state disagreements. SWIFT exclusions for Belarusian banks remain in force with no easing. Switzerland adopted additional Belarus measures in February 2026 mirroring the EU’s 19th package.
U.S. sanctions: selective easing
The U.S. has moved in the opposite direction with calibrated, targeted easing — while keeping the core sanctions architecture (EO 13405 and EO 14038) intact:
- November 2025: OFAC delisted Belavia and permitted limited transactions involving three aircraft tied to the presidency.
- 26 March 2026: OFAC issued Belarus General License 14, authorising transactions involving Belinvestbank. Simultaneously, OFAC rescinded Directive 1 under EO 14038 (lifting restrictions on new long-term debt of the Belarus Ministry of Finance and the Development Bank of the Republic of Belarus), and removed Belaruskali and Belarusian Potash Company from the SDN list.
Important caveat on secondary sanctions: Although the U.S. Belarus sanctions regime is technically “targeted” rather than comprehensive (unlike Iran or Cuba), EO 14038 explicitly authorises secondary sanctions on non-U.S. persons. Foreign persons risk being designated as SDNs if they operate in certain sectors or facilitate sanctions evasion. Third-country investors in Belarus should not assume they are outside U.S. enforcement reach.
International trade environment: EU tariffs
The EU adopted tariffs on agricultural products and fertilisers from Belarus (and Russia) in June 2025. These are not flat duties but follow a phased escalation schedule designed to become progressively more prohibitive through 2028. For combined fertilisers, tariffs rise from EUR 95 per tonne at introduction to EUR 430 per tonne by July 2028.
The policy goal is to reduce EU dependence on Belarusian and Russian fertiliser imports, though the EU currently produces only 45–50% of its own fertiliser demand. Hungary has pushed back against the tariff regime, but the measures remain in force.
For investors considering Belarus-based production for EU export, these escalating duties fundamentally change the margin structure. Agricultural and fertiliser projects that depend on EU market access need to model landed costs through 2028 and beyond.
Banking, payments, and compliance risks
Banking is the single most practical constraint for foreign investors in Belarus. EU sanctions have created severe limitations:
- SWIFT exclusions: Several Belarusian banks remain excluded from SWIFT, making international transfers through those institutions impossible via standard channels.
- EU transaction bans: As of December 2025, EU residents cannot conduct any financial or business transactions with Alfa-Bank Belarus, Sberbank Belarus, or VTB Bank Belarus.
- Correspondent banking: The EU prohibits new deposits and imposes broad restrictions on dealings with Belarusian state-owned banks and the Central Bank of Belarus.
- Asset freezes: Extensive under Regulation (EC) No 765/2006, regularly updated and expanded.
The U.S. picture is more nuanced following the March 2026 easing. Belinvestbank is now covered by General License 14 (transactions authorised), and Directive 1 debt restrictions on the Development Bank have been rescinded. However, broader Belarusian state-linked financial institutions continue to face targeted U.S. sanctions and high de-risking from Western correspondent banks.
In practice, this means investors must carefully select banking partners, expect extended payment timelines, and may need to route transactions through non-sanctioned intermediaries. Maintaining clear documentation and compliance procedures is essential.
Market access and implications for exporters
For Belarus-based exporters, EU-bound shipments in tariffed sectors now face escalating duty burdens, while sanctions tighten due diligence, banking, and logistics. The combined effect increases transaction costs, lengthens timelines, and may necessitate supply-chain reconfiguration.
Risk is not uniform. The U.S. easing for potash exporters (Belaruskali delisted March 2026) reflects concern about global agricultural supply chain stability and fertiliser price inflation. This may create selective openings for commodity-focused investors, while other sectors remain heavily restricted.
EAEU membership provides a partial offset: Belarus-based operations can access the Russian, Kazakh, Kyrgyz, and Armenian markets with reduced trade barriers. For investors whose primary market is the EAEU rather than the EU, the sanctions impact on market access is less acute — though banking and payment frictions still apply.
Sanctions compliance checklist for investors
Before committing capital to a Belarus-based project, work through each of these practical feasibility checks:
- Screen counterparties: Check all Belarusian partners, banks, insurers, and service providers against EU consolidated sanctions lists, OFAC SDN lists, and UK sanctions lists. Ownership structures matter — 50% ownership rule applies.
- Confirm banking access: Identify which Belarusian banks can process your transactions. Verify SWIFT connectivity, correspondent banking relationships, and whether your home-country bank will process Belarus-related transfers.
- Map sector exposure: Determine whether your investment touches restricted sectors (military-industrial, certain chemicals, electronics, dual-use goods). Export bans may prevent shipment of critical inputs.
- Assess EU tariff impact: If your project targets EU markets, model the phased tariff schedule through 2028. Calculate landed costs at each escalation step.
- Evaluate secondary sanctions risk: U.S. EO 14038 can reach non-U.S. persons. Assess whether any aspect of your investment could trigger U.S. designation.
- Plan payment routes: Map the full payment chain from your jurisdiction through intermediary banks to Belarus. Identify potential chokepoints and alternative routes.
- Document everything: Maintain comprehensive compliance records. Decree No. 10 VAT refunds require contractual clarity and auditability to withstand heightened scrutiny.
Belarus vs Armenia for investors
If sanctions risk makes Belarus impractical, or if you need a regional hub that offers operational stability alongside Belarus-based activities, Armenia provides a lower-friction alternative within the same EAEU market:
| Factor | Belarus | Armenia |
|---|---|---|
| Sanctions exposure | High (EU + partial U.S.) | None |
| Corporate tax rate | 20–25% | 18% (standard); micro/IT lower |
| Banking access | Restricted (SWIFT exclusions, EU bans) | Open (SWIFT, international correspondents) |
| EAEU market access | Yes | Yes |
| EU market access | Restricted (tariffs, sanctions) | GSP+, CEPA agreement |
| Investor residency | ~USD 200,000 minimum investment | Business-based residence readily available |
| Business setup speed | Weeks to months (bureaucratic) | 1–2 weeks |
Many investors pursuing Belarus incentives simultaneously establish an Armenia platform for operations, treasury, and IP — using Armenia’s open banking, straightforward company registration, clear tax rules, and accessible residency and visa pathways as a stable operational base.
Frequently asked questions
What is Decree No. 10 and how do VAT refunds work?
Presidential Decree No. 10 of 6 August 2009 enables Belarus to sign state-guaranteed investment contracts granting incentives. A headline benefit is full refund of VAT paid on imported equipment and goods used for the contracted project, directly reducing effective capex outlays. The decree also enables land acquisition without public tender, customs duty relief, and reduced corporate income tax for specified periods.
Does Belarus have a citizenship-by-investment or golden visa programme?
No. As of April 2026, Belarus has neither a formal CBI programme nor a branded “golden visa.” However, a permanent residence pathway exists for investors meeting a minimum of 15,000 basic units (~USD 200,000), requiring physical presence of at least half of each year, with naturalisation eligibility after seven years. Belarusian lawmakers are reportedly considering a draft law to simplify citizenship for foreign investors, but no legislation has been adopted.
What changed in EU sanctions against Belarus in late 2025?
The EU’s 19th sanctions package (October 2025) added 64 new asset-freeze listings, expanded export bans on goods facilitating Belarusian military systems, and banned EU residents from all transactions with Alfa-Bank Belarus, Sberbank Belarus, and VTB Bank Belarus effective 2 December 2025. SWIFT exclusions for Belarusian banks remain in force. A 20th package has been discussed but not adopted as of April 2026.
Has the U.S. eased sanctions on Belarus in 2026?
Yes, selectively. On 26 March 2026, OFAC issued General License 14 authorising transactions with Belinvestbank, removed Belaruskali and Belarusian Potash Company from the SDN list, and rescinded Directive 1 under EO 14038. These follow the November 2025 delisting of Belavia. However, the core sanctions architecture under EO 13405 and EO 14038 remains in place, and EO 14038 authorises secondary sanctions on non-U.S. persons.
How do EU tariffs affect Belarusian exporters?
EU tariffs on Belarusian fertilisers and agricultural goods follow a phased escalation from EUR 95 to EUR 430 per tonne for combined fertilisers by July 2028. These duties are designed to become progressively prohibitive. Exporters targeting EU markets should reassess pricing, margins, and routing, and consider whether EAEU or other non-EU markets offer viable alternatives.
Can I use Armenia as a base while investing in Belarus?
Yes. As both countries are EAEU members, establishing a parallel Armenia platform is a common strategy. Armenia offers open international banking (no SWIFT restrictions), straightforward business registration (1–2 weeks), accessible residency permits, and no sanctions exposure. Many investors use Armenia for treasury, management, and IP functions while pursuing Decree No. 10 incentives in Belarus.
Belarus investment migration in 2026 is a trade-off between substantial, contract-based tax benefits and an increasingly complex sanctions environment. The EU is tightening while the U.S. is selectively easing, creating a mixed risk profile that requires careful, jurisdiction-specific analysis. If you need a resilient base while pursuing Decree No. 10 incentives, consider regional diversification — Armenia offers predictable residency, straightforward business setup, and clear tax rules.
Contact us to assess eligibility, structure your Decree No. 10 contract, and build a compliant, multi-jurisdiction strategy.
