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Update - Kazakhstan's Additional Conditions for Application of Tax Treaty Benefits Apply for Treaties Amended by BEPS MLI

13 February 2023

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Approved Changes

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Kazakhstan

Kazakhstan's State Revenue Committee recently issued a release regarding the application of tax treaty benefits in cases where an applicable treaty has been amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). As previously reported, Kazakhstan amended the Tax Code with effect from 1 January 2023 to include conditions for the application of exemptions or reduced withholding tax rates by a tax agent (payer) on passive income paid to a non-resident under a tax treaty where the non-resident is a related party. The additional conditions include that the income must...