Expert Opinion: Soyuzkali May Have Permanent Office in Belarus
OREANDA-NEWS. September 21, 2012. Soyuzkali – a joint trading company headquartered in Switzerland to promote exports of potash fertilizers manufactured by OJSC Uralkali and OJSC Belaruskali on overseas markets – may choose to establish a permanent representative office in Belarus, provided Soyuzkali has a control centre in Minsk.
Andrei Chumakov, chief tax&law expert with Ernst&Young Belarus, made a statement to this effect in an interview.
The expert referred to the agreement on avoidance of double taxation signed by Belarus and Switzerland. The document implies that the Swiss-based company may have a permanent representative office in Belarus, provided there is a Belarus-based control centre to manage Soyuzkali’s overseas activities.
From the practical point of view, it means that Soyuzkali’s permanent representative office in Belarus will have to get an official registration and pay local taxes, including the tax on incomes generated by the Swiss-based company.
In this context, the expert doubts whether Soyuzkali will be in a position to make a proper use of the advantages of the Swiss tax legislation.




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