Kazakhstan: Tax measures clarifying taxation of nonresidents, tax-free corporate transfers, treaty benefits

Kazakhstan: Clarifying taxation of nonresidents

New law No. 382-VI includes the following measures that generally are effective 1 January 2021:

  • Regarding the taxation of nonresidents, an expanded list of information that certain banks and financial institutions must provide to the tax authorities, and also allowing nonresidents to apply for mutual approval procedures
  • Introducing mechanisms to allow for tax-free transfers of assets within a group of companies
  • Restricting an automatic application of tax treaties provisions and regarding a tax exemption for income payable to related parties (for instance, to clarify that concerning payments of dividends, interest, and/or royalties, relief under a tax treaty would not apply if the dividends, interest or royalties relate to a Kazakh permanent establishment of a nonresident recipient of such payments)
  • Providing rules regarding application of the Multilateral Instrument (MLI) regarding income payable to residents of MLI signatory countries

For more information, contact KPMG’s Global Head of International Tax:

Rodney Lawrence | +1 (312) 665 5137 | rlawrence@kpmg.com


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