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Kazakhstan Introduces Nexus Rules for IP Income

30 December 2022

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Approved Changes

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Kazakhstan

Kazakhstan's State Revenue Committee has issued a release on Ministerial Order No. 1287 of 15 December 2022, which approves the rules for determining income from intellectual property (IP) and IT services that qualifies for an income tax exemption (100% reduction) for participants in the "Astana Hub" or special economic zones (SEZ). With respect to IP income, the order sets out the rules for applying the nexus approach in accordance with OECD BEPS Action 5, using the following formula: (A+B) * 1.3 / (A+B+C+D), where: A is the direct costs incurred by the taxpayer in relation to the development of intellectual...