Kazakhstan has published the Government Resolution of 18 October 2024 for the signing of an amending protocol to the 1996 income and capital tax treaty with Iran. The protocol includes amendments in line with the BEPS MLI, including the replacement of the title and preamble, a new article on permanent establishment, a 365-day holding condition for reduced dividend withholding, a new article on entitlement to benefits, etc. The protocol will be the first to amend the treaty and must be signed and ratified before entering into force.