HomeHTPHow to Write a Winning HTP Business Plan: Structure, Common Rejection Reasons, and Real Examples
How to Write a Winning HTP Business Plan: Structure, Common Rejection Reasons, and Real Examples
By Spex Team
04.06.2026
For IT companies looking at Belarus, the High-Tech Park is the prize that makes the rest of the paperwork worth doing. A 1% unified tax on revenue, no VAT on exports, zero corporate profit tax on qualifying activity, and payroll contributions tied to the national average wage instead of actual salaries — the combined effect on a software company’s P&L is hard to beat anywhere in the region.
None of that turns on, though, until the HTP Supervisory Board signs off on your application. And the approval comes down to one document.
Your business plan.
It isn’t a pitch. It isn’t investor materials you can repurpose. It’s a regulatory submission with its own logic, its own audience, and its own way of being read. The board uses it to decide whether your company qualifies under Decree No. 8 — and whether you actually intend to do high-technology work in Belarus, or just want your name attached to a tax-friendly jurisdiction. The dossiers that get approved on the first pass tend to look quite different from what most foreign founders draft on instinct.
What follows is what we’ve learned from working on more than 50 of these submissions: how to structure the document, where applications usually go wrong, and the small things that quietly separate the approved files from the ones sent back for rework.
What the Supervisory Board is actually looking for
The board meets roughly once a quarter. It works through whatever applications have accumulated since the last session, so timing matters more than people expect — submit a week after a session ends and you’re effectively waiting three months for the next one.
What the members care about isn’t formatting. They want to know four things. Does what you propose to do actually fit one of the 30-plus categories of high-tech activity under Decree No. 8? Are your numbers realistic, or did someone in marketing write them? Is there a real R&D component, or is the “innovation” just a paragraph of buzzwords? And will you genuinely operate in Belarus — hiring people, building IP, exporting — rather than treat the residency as a tax wrapper?
The activities list and the underlying regulatory framework are both available on the HTP Administration site. It’s worth a careful read before anyone starts drafting.
The structure that works
Successful business plans tend to run between 15 and 20 pages and follow the format approved by the Belarusian government. The exact section ordering moves around a bit, but the content is consistent.
1. Company information. Full legal name, registration details, ownership structure, founders (including foreign ones), and management. Authorized capital, share distribution, the appointed director of the Belarusian entity. Vague ownership descriptions trigger follow-up questions every time, so spell it out — even if the parent structure feels obvious to you, it isn’t obvious to a reviewer seeing it for the first time.
2. Description of planned activities. This is where most plans live or die. Describe what your company will do in language that maps directly onto the activity list under Decree No. 8. If you’re building SaaS for healthcare, don’t just say “we work in healthtech.” Name the specific approved activity — software development, data processing, whichever one fits — and explain how your product is an instance of it.
If part of your business sits outside HTP-eligible activities, separate the eligible part into a distinct revenue stream and say so. Mixed activities are workable. Hidden mixed activities aren’t.
3. Product and market description. What you’re building, who buys it, and where the buyers live. Strong applications show real export orientation: international customers, products sold abroad, services delivered cross-border. HTP exists to grow Belarusian IT exports, so a plan with mostly local revenue needs a good reason behind it.
4. Financial projections. Three years, minimum. Revenue, expenses, profit, taxes payable. The numbers don’t need to be huge — but they do need to add up. Headcount has to match payroll. Office costs have to match the operation you’re describing. Year-three revenue can’t quintuple while costs sit flat. Newly formed Belarusian subsidiaries don’t have to submit historical financials, but the projections inside the plan have to be internally consistent on their own.
5. Investment and operational plan. Spending on equipment, software, the office, and the team, plus a hiring schedule that breaks out who you’re bringing on in which year and what their role will be. What the board is really checking for here is evidence of a genuine operation — staff, infrastructure, actual investment — rather than a shell entity dressed up to sit inside the tax regime.
6. R&D and innovation focus. Decree No. 8 exists to grow high-technology work in Belarus; it wasn’t designed to subsidise body shops. The R&D section needs to reflect that. Name the products you’re building, the research directions you’re committing to, and the technology stack the work will actually live on. Putting “we’ll innovate in AI” on the page without anything concrete to back it up is one of the surer ways to draw a resubmission request.
7. Compliance and governance. This section covers your governance setup, internal control framework, and the way you’ll meet ongoing HTP reporting obligations. If any part of the business touches crypto-assets or tokens, you’ll also need to lay out an AML/CFT framework that lines up with FATF recommendations — generic compliance language in this area gets the file kicked back faster than almost anything else.
8. Annexes. Charter, certificate of state registration, founder ID documents, director appointment, certified translations. Missing annexes are responsible for a surprising number of resubmissions — a boring failure mode, but a common one.
Why applications get rejected
Rejection isn’t usually a surprise once you’ve seen enough files. The reasons cluster into a fairly short list, and almost every one of them is preventable before the dossier ever reaches the Supervisory Board.
The activity doesn’t fit Decree No. 8
This is the single most common dealbreaker. Decree No. 8 spells out which categories of work qualify for HTP residency, and anything outside that list — media production, classical marketing services, generalist consulting, anything that just touches IT rather than living inside it — gets stopped at the door. Before drafting a single line of the plan, take your revenue model and map each stream to a specific approved activity. If the mapping needs creative interpretation to work, the application probably won’t survive review either.
The financials don’t hold together
Inconsistency is what gets caught fastest. Revenue forecasts that aren’t backed by a headcount plan. Three-year projections that triple revenue without changing the cost base. Salary lines that quietly disagree with the team size described two sections earlier. Reviewers see thousands of these files. They spot it when the numbers tell different stories in different places.
There’s no real R&D underneath
Pure outsourcing — staff augmentation or contract development with no proprietary product, no research direction, and no technology investment of your own — is the most frequent substantive ground for refusal. The HTP regime exists to develop high technology inside Belarus. A plan that reads as a tax-optimized billing arrangement won’t fit that purpose, however well it’s written.
Ownership and management aren’t clearly documented
Beneficial ownership has to be traceable. The local director has to hold genuine executive authority, not a paper appointment. Foreign founders’ ID documents need to meet Belarusian apostille and certified-translation requirements, and getting those finalized usually takes longer than teams plan for. Any ambiguity here stalls the entire file.
Translation and formatting issues
Russian is the language of the official submission. Bilingual plans are fine — most foreign applicants prepare one — but the Russian version is what gets reviewed, and the translation has to be certified. Non-certified translations, missing notarizations, and mismatches between the Russian and English texts all come back as resubmission requests.
Weak AML/CFT framework for crypto and token projects
If your business touches virtual assets in any form, generic compliance language doesn’t pass. The plan needs explicit customer identification procedures, demonstrated financial stability, and FATF-aligned processes. Skipping this section, or filling it with boilerplate, is one of the more reliable ways to get sent back.
The plan signals you don’t really intend to operate locally
Some applications technically check every box and still get rejected because the file reads as if Belarus is just a jurisdiction on paper. No local hiring. No real investment. Every dollar of revenue is routed offshore. Members of the HTP Supervisory Board read between the lines on intent, and substance consistently outweighs presentation when the two diverge.
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Beyond avoiding the obvious mistakes, the dossiers that clear the first review cycle share a few characteristics. None of them are mandatory, but they show up consistently.
A focused product story. One or two clearly defined products, named target markets, identifiable buyers. Plans that try to cover ten activity areas at once read as unfocused and rarely fare well.
Year-one numbers that look like real year-one numbers. Modest revenue, a visible build-out phase, growth concentrated in years two and three. Plans showing a five-person team generating $5M of revenue in month one aren’t taken seriously.
Headcount that matches the work. A 15-person team doing “machine learning research” reads as plausible. The same roadmap with three people doesn’t.
A documented IP structure. Where source code, licenses, and intellectual property actually sit — in the Belarusian entity, in the parent, licensed in from elsewhere — needs to be explicit. Ambiguity here creates problems at admission, and again later during the annual audit of HTP residents, where the business plan becomes the baseline against which the rest is measured.
An honest export number. The applications that land cleanly usually show 80 to 100% of revenue coming from outside Belarus, with named international clients or a believable go-to-market story behind the figures. If the bulk of your revenue comes from inside the country, you’ll need to address why on the page — it’s the kind of mismatch the board picks up on quickly.
Alignment with the tax framework. The 1% unified tax, the reduced payroll contributions, and the dividend treatment aren’t details that live quietly at the back of the plan. They shape how revenue is categorised across the document, how hiring is justified, and how distributions are eventually structured. Reading through HTP taxation in practice before you lock down the financial section saves rework later.
A few practical things to do before you submit
Run the eligibility check first. If your business doesn’t fit an approved activity, no amount of polishing fixes that.
Reconcile every number across sections. Headcount, revenue, costs, capex — they all have to tell the same story when read together.
Use a translator who understands tax and legal terminology. A general-purpose service will technically translate the words and quietly mistranslate the meaning.
If your business touches crypto, tokens, or financial services, treat the AML/CFT section as a real piece of work, not a final paragraph.
Get someone who has seen approved plans review yours before submission. First drafts almost always improve under informed feedback.
The full picture of the HTP regime — from entity formation through admission and into ongoing compliance — is laid out on the Belarus High-Tech Park page. For broader context on Belarus’s investment incentives, the Ministry of Economy publishes the official overview.
FAQ
How long does the business plan need to be?
Fifteen to twenty pages, in most cases. Shorter plans tend to drop something the board expects to see; longer ones dilute the parts that actually matter. There’s a template approved by the Belarusian government — work inside it rather than reinventing the structure.
Which language does the business plan have to be in?
Russian. A parallel English version is fine for your own team, and most of our clients keep one, but the Russian text is the official submission. Any translation has to be certified — machine translation isn’t a workable shortcut here, and the board will catch it.
If the board sends the file back, is that a rejection?
Usually no. Most “rejections” are resubmission requests with a specific list of things to fix. Outright denials are less common and tend to come down to two situations: the activity doesn’t fit any approved category under Decree No. 8, or the file reads as though you don’t really plan to operate in Belarus. Both are avoidable if the eligibility work happens before drafting starts.
Do we need historical financials if our Belarusian entity is brand new?
No. New subsidiaries have nothing to attach, and the board doesn’t expect anything. The projections inside the business plan are what gets reviewed. An existing entity is a different story — it has to submit historical statements as part of the dossier.
Can the plan be updated after admission?
Yes, and most companies do at some point. Material changes — to activities, ownership, beneficial owners, management — have to be reported to the HTP Administration. Larger pivots, like moving into a new line of business, can trigger a formal amendment of the residency terms. The plan isn’t a static document once you’re a resident./
Final thoughts
The HTP business plan keeps doing work long after the Supervisory Board signs off on it. It sets the boundaries of what your company can charge under the 1% regime. The activity scope it describes is also what audits will measure you against later. And whenever something material changes about your business, this is the file the HTP Administration reaches for first. That isn’t a theoretical observation — every resident eventually has reason to revisit what was filed at admission. The structural requirements haven’t really shifted in years, and the failure patterns are well understood by now. What separates a clean first-pass approval from a resubmission usually has less to do with the strength of the underlying business than with how carefully the plan itself was put together.
For companies preparing a submission, or evaluating Belarus as part of a broader market entry strategy, our team provides end-to-end support for HTP admission — including eligibility assessment, business plan development, dossier preparation and submission, and post-approval compliance management.
About the Author
Spex Team
Daria Fedorova is a marketing expert with years of experience supporting businesses entering and expanding in the Belarusian market. She combines strategic marketing expertise with knowledge of legal and administrative processes, helping companies successfully establish and grow their presence in the country.
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