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Kazakhstan: Multilateral instrument (MLI) is ratified

Kazakhstan: Multilateral instrument (MLI) is ratified

The government in Kazakhstan on 20 February 2020 ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the multilateral instrument or “MLI”). After the MLI enters into force, the procedure for the application of Kazakhstan tax treaties will change.


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The purpose of the MLI is to address tax treaty abuse triggering tax evasion or avoidance. The MLI:

  • Will apply to only those tax treaties that are in force between parties to the MLI
  • Establishes a minimum standard to be met by all parties to the MLI and optional provisions applicable with respect to a tax treaty only if both contracting states choose to apply it

The MLI will enter into force on the first day of the month following a three-month period beginning on the date that Kazakhstan deposits its ratification instrument with the OECD. Once in force, the provisions of the MLI will apply from 1 January of the year following its entry into force with respect to withholding taxes, and for all other taxes with respect to tax periods beginning on or after the expiration of a six-month period following the date of entry into force.

After the MLI enters into force, the tax treatment of a cross-border transaction will depend on the provisions of local tax legislation, an applicable tax treaty and the MLI (if the MLI positions of the contracting states match).

Read a March 2020 report [PDF 716 KB] prepared by the KPMG member firm in Kazakhstan

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