For international tech groups, the list of places to build an R&D center outside the EU has narrowed to a handful of jurisdictions with special IT regimes. Three of them come up in almost every conversation we have with founders and CFOs: Belarus’s Hi-Tech Park (HTP), Uzbekistan’s IT Park and Armenia’s state support programme for the high-tech sector.
2027 is a year to make this decision carefully, because the rules are moving. In Uzbekistan, the full IT Park package runs until 1 January 2028, after which only export-led residents keep most of the benefits. In Belarus, the 13% income tax rate for HTP employees is fixed until the start of 2028. Armenia is in the middle of a seven-year incentive package that ends in 2031. A center you open in 2027 will spend most of its life under the next set of rules, not the current one.
Below we compare the three on what actually drives the cost and risk of an R&D operation: corporate and payroll taxes, how long the regime is guaranteed, the depth of the talent pool, how easy it is to hire foreigners, and the banking and sanctions picture.
The Hi-Tech Park is the oldest of the three regimes. It was created in 2005 and rebuilt in 2017 by Decree No. 8 on the development of the digital economy. It is not a physical campus: any Belarusian legal entity carrying out activities from the approved list can become a resident, wherever its office is located. The special legal regime is set to run until 1 January 2049, a horizon nobody else in the region offers.
The talent pool is also the deepest of the three. More than 60,000 engineers, analysts and designers work for HTP residents, many of them with years on long-running product and outsourcing accounts for Western clients. For an R&D center that needs architects, team leads and senior developers rather than only juniors, this is often the deciding factor.
On tax the fundamental benefit is this: rather than the normal 20% profit tax and VAT on qualifying income, a resident pays 1% of gross revenue to the Park each quarter. Export of software and IT services is outside the scope of Belarusian VAT. Foreign corporate shareholders pay 5% tax on dividends (or less where a tax treaty applies) and income of foreign companies from the sale of their shares in a resident is taxed at 0%. That last point is important if you ever do plan an exit.
Payroll is where the Belarusian model really pays itself off for the senior teams. Employer social contributions (FSZN) are only payable up to the national average monthly wage so there is nothing due on the part of any salary above that level. The higher the salary the greater the saving. Employees pay 13% personal income tax (Decree No. 8 is 9% but the Tax Code has maintained 13% since 2021 and that extension is until 1 January 2028).
Residents can also use legal instruments that international investors expect, such as options, convertible loans, and non-compete and non-solicitation agreements. Foreign specialists can be hired without work permits, and foreign employees and founders of residents can stay in Belarus visa-free for up to 180 days a year.
Admission is project based rather than formula based. There is no minimum headcount or minimum turnover. The HTP Supervisory Board will assess the business project and will usually make a decision in the region of 4-6 weeks. Most of the work is in that document and it has to be in the exact language of the HTP Regulations. How well you prepare for HTP residency is what will determine whether your start is smooth or whether you end up with months of back and forth.
The trade-off is external rather than legal. Belarus is under EU, UK and US sanctions, which complicates banking and payments with Western counterparties, and air links with the EU are cut, so travel from Europe goes through third countries or overland. We come back to this in the risk section below.
Uzbekistan opened its first IT Park in Tashkent in July 2019, building on a 2017 presidential decree. Like the HTP, residency is a status rather than an address, and residents now operate both in the capital and across the regions.
The package on paper is the most generous of the three. Until 1 January 2028 residents are completely exempt from all taxes and all mandatory contributions to state trust funds (social tax included), as well as from customs payments on imported equipment and software which is not manufactured locally. In return they pay 1% of their total revenue to the IT Park directorate. Salaries of employees are taxed at a flat 7.5%.
The key date for anyone planning in 2027 is 1 January 2028. Law No. ZRU-1014 of 24 December 2024 extends the tax benefits, except the VAT exemption, until 1 January 2040, but only for residents whose exports of permitted activities exceed 50% of total income in a calendar year. IT education providers have a separate test based on how many graduates find jobs with exporting residents. A captive R&D center billing its foreign parent should clear the export test comfortably. A company that also serves the domestic market needs to model its post-2028 numbers without the package. The 7.5% salary tax is also tied to 2028 in the original decree, so it is worth confirming how it will apply after that date before fixing a long-term budget.
The momentum is very real. In the first half of 2026 608 export oriented companies joined the park (that’s 178% more than the same period last year) and the number of IT Park residents with foreign capital reached 1,095. Members’ service exports in Jan to June 2026 came to $392.5 million with North America the largest destination.
For foreign staff, the IT visa is issued for up to three years to specialists, investors and founders of residents; specialists have to show IT income of at least $30,000 over the previous 12 months. Residents are not required to own or rent an office.
The main constraint is depth at the senior end. The ecosystem is young, and most residents joined in the last few years, so engineers with a decade of product experience are harder to find than in Minsk. Many companies bring in team leads from abroad for the first phase. For QA, support, data operations and mid-level development, however, the cost-to-quality ratio is hard to beat.
Armenia is taking a different approach. There’s no park status to apply for. The route is via the Law on State Support for the High Tech Sector (passed in December 2024) which provides a range of incentives to qualifying companies from 2025 to 2031 (with the possibility of extension). It’s effectively replaced the previous IT start-up certificate scheme whereby employees were subject to 10% income tax rather than the standard 20%.
The starting point is higher than in the other two countries: corporate income tax is 18% and personal income tax is a flat 20%. The incentives then work on specific costs rather than replacing the tax system as a whole:
Access to the high-tech incentive package depends on membership of the High-Tech Registry, more than 90% of revenue from high-tech operations and a clean tax compliance record.
For an R&D centre the salary deduction and the researcher rate are the two things that really matter. The 1% turnover tax looks very attractive but it’s designed for small companies. A fairly large centre owned by a foreign group will normally be in the general regime and the actual burden will be a function of how much of the payroll is R&D.
Armenia’s tech sector employed around 41,500 people at the end of 2024 and represents 7-8% of GDP. English is widely used in tech teams and banking with Western counterparties is the norm. The 2022 relocation wave brought in a significant number of experienced engineers and managers. The other side of the coin is scale. A 150 person centre is a very significant hire in such a small market and there is fierce competition for senior engineers in Yerevan which has a bearing on the salary levels.
The table sets out the rules as they are in October 2026. Take it as a point of departure for your own model rather than as the definitive answer, as the parameters in all three countries are revised on a regular basis.
| Regime horizon | Until 1 January 2049 | Full package to 1 January 2028; exporters (over 50% of income) to 1 January 2040, excluding VAT | 2025–2031, extension possible |
| Corporate taxation | 1% of revenue in place of profit tax and VAT | Exempt from all taxes; 1% of revenue to the IT Park | 18% CIT; 200% deduction for R&D salaries (capped at 50% of taxable income); 1% turnover tax for eligible smaller firms |
| Employee income tax | 13% (fixed to 1 January 2028) | 7.5% (to 1 January 2028) | 20%; 10% for certified researchers |
| Payroll incentive | Social contributions charged only up to the national average wage | Social tax exemption | 60% income tax recovery for new hires and labour migrants |
| Talent pool | 60,000+ specialists at HTP residents | 1,095 residents with foreign capital; 608 new exporters in H1 2026 | About 41,500 tech employees (end of 2024) |
| Entry route | Belarusian entity plus Supervisory Board decision, usually 4–6 weeks | Local entity plus IT Park residency | Local entity plus High-Tech Registry |
| Main risk | Sanctions, banking and payments | 2028 transition, thinner senior layer | Small, expensive talent market |
Tax rates are the easy part of the comparison. What usually decides the outcome is whether money, people and intellectual property can move without friction.
Belarus carries the heaviest external risk. Sanctions imposed by the EU, the UK and the US mean that some banks and payment routes are closed, Western clients may run enhanced due diligence on a Belarusian vendor, and bank onboarding and currency control require more documentation than they did a few years ago. None of this blocks a legitimate R&D operation, but it has to be designed in from day one: the contract structure, the paying entity, the bank and the settlement currency all need a deliberate choice.
Uzbekistan’s primary risk is regulatory change rather than sanctions. The policy has been generous but it’s been very much a moving target with benefit periods, eligibility criteria, dividend rates and visa rules all having been changed since 2019. The 2028 transition is still ahead. Build in some flexibility so that a change to one rule doesn’t necessitate a complete rebuild.
Armenia’s risks are predominantly commercial. The cost curve in a small market is steep when demand goes up and the incentive window currently ends in 2031. Armenian banks also have very rigorous compliance checks on cross-border flows (especially where Russian counterparties are involved) which is of course relevant if you have any clients or shareholders in Russia.
Wherever you go, decide early where the intellectual property will sit. Some groups have the R&D center develop under contract and assign everything to the parent; others keep the IP in a holding company and let the local entity use it under licence. In the second case, the royalty payments to that holding need to be priced and documented well enough to survive a tax audit, and the same logic applies in Tashkent and Yerevan.
The correct jurisdiction is less to do with the headline rates and more to do with the shape of your team and the make-up of your group. Those are the patterns we see most frequently.
You’re a Western funded startup with a small senior team. If your investors are after simple banking, EU-friendly appearance and a team of 10-30 engineers then Armenia is very much the right fit. The incentives are geared towards R&D payroll and new hires rather than turnover so the benefits actually grow in line with the work you do there.
You’re scaling on cost. For large QA, support, data ops or mid dev teams serving export clients, Uzbekistan has the lowest headline taxes and the pool is growing rapidly. Keep export revenue at over 50% of total revenue so the benefits continue after 2028 and budget for experienced team leads in the first few years.
You need senior engineers quickly. If the plan is 40 to 100 experienced engineers within a year for complex product work, Belarus usually wins on depth and on payroll cost per senior head. It works best for groups whose clients, investors and banks are comfortable with Belarusian exposure. Many companies start by hiring through an Employer of Record in Belarus while the entity and the HTP application are prepared, then move the team across once residency is granted.
You want a mix. Some groups have split the work: a senior core in Minsk for the architecture and complex bits with a scaling team in Tashkent; or a small Yerevan outfit for the Western facing roles sitting alongside a larger engineering hub elsewhere. In that case you’ve got to design your transfer pricing and IP flows for the whole group, not country by country.
On headline rates Uzbekistan until 2028: no corporate tax, no social tax and 7.5% income tax on salaries (with a 1% revenue deduction). Belarus is pretty close for senior-heavy teams as social contributions cease at the national average wage. Armenia starts from the highest base but its R&D salary deduction and 10% researcher rate bring it down for genuine R&D payroll. The real answer is going to be down to your salary mix so you’ll need to run the numbers on your own headcount plan.
The special legal regime of the Hi-Tech Park runs until 1 January 2049 under Decree No. 8. Individual parameters can still change. The employee income tax rate, for example, has been 13% rather than the decree’s 9% since 2021 and is currently fixed until 1 January 2028. The corporate side, with 1% of revenue paid in place of profit tax and VAT, has stayed stable.
From 1 January 2028 to 1 January 2040, the tax benefits other than the VAT exemption continue only for residents whose exports exceed 50% of total income in a calendar year, or for IT education providers that meet a graduate employment test. Residents that do not qualify move to the general tax regime.
Yes, in all three countries. HTP residents hire foreigners without work permits, and their foreign employees and founders can stay visa-free for up to 180 days a year. Uzbekistan issues IT visas for up to three years to specialists, investors and founders of IT Park residents. Armenia’s package includes a 60% income tax refund linked to qualifying labour migrants hired by high-tech companies.
Yes, although local statutory roles still have to be filled. Most international groups with a Belarusian subsidiary already manage it remotely, with a local director, accountant and HR function handling filings, payroll and day-to-day compliance while the headquarters sets strategy and budgets.
There is no single winner. Belarus offers the longest-dated regime, the deepest pool of senior engineers and a payroll model that rewards high salaries, at the price of sanctions-related friction that has to be managed deliberately. Uzbekistan offers the most generous package and the fastest growth, but the 2028 transition and a thinner senior layer need planning. Armenia offers straightforward banking and incentives aimed squarely at R&D payroll, in a small and increasingly expensive market.
The decision comes down to your own numbers: headcount by seniority, where your clients pay from, where the IP will sit and how much sanctions exposure your board is willing to accept. If Minsk is on your shortlist, talk to our team and we will model the HTP option against your alternatives before you commit to a location.
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