Who will pay offshore duty in the enforcement procedure?

At the procedure of debt recovery in favor of a non-resident some difficulties, related to participation in the enforcement, as well as actual transfer of money may arise. Thus, Belarusian tax legislation sets an obligation to pay an offshore duty before transferring money to the debtor. Here is a question: who should pay offshore duty – government body, represented by the enforcement agent, or the creditor itself? 

Full version of the article in Russian, published in “Industrial-and-trade law” magazine, you will find here.