Nowadays, international collaboration of local businesses with foreign partners has already become an essential component of the country’s economy. Such collaboration results in creation of the new legal entities with foreign participation, rendering different kinds of services, i.e. consulting, management, financial, manpower services, etc. Therefore,a state policy on international taxation has a direct impact on the country’s investment attractiveness index.
Still, the complexity of Kazakh international tax legislation and inconsistent practice on application of the tax legislative norms create the base for the tax complications and problems in the local Kazakh companies in their cooperation with the foreign partners.
Two principles are applied in taxation of incomes earned by foreign legal entities and foreign individuals from their activity in Kazakhstan: residency and territoriality (apportionment). The principle of residency implies that all incomes of Kazakh resident, earned in all countries, are to be taxed by Kazakh income tax. The principle of territoriality (apportionment) implies that all incomes earned on the territory of Kazakhstan as well are taxed by Kazakh income tax.
Other countries can apply these principles as well. Simultaneous application of these principles by two countries towards one tax object leads to the international double taxation. Kazakhstan endeavors to resolve these issues, has been concluding the international double tax treaties (conventions) with other committed foreign countries for avoidance of double tax casesand income and capital gains tax evasions. As of January 1, 2010, Kazakhstan has concluded the treaties with 49 countries, and has ratified 39 treaties.
Select a country
Armenia
Austria
Azerbaijan
Belarus
Belgium
Bulgaria
Canada
China
Czech Republic
Estonia
Finland
France
Georgia
Germany
Great Britain
Hungary
India
Iran
Italy
Japan
Korea
Kyrgyzstan
Latvia
Lithuania
Luxemburg
Malaysia
Moldova
Mongolia
Norway
Pakistan
Poland
Romania
Russia
Singapore
Slovakia
Sweden
Switzerland
Tajikistan
the Netherlands
Turkey
Turkmenistan
Ukraine
USA
Uzbekistan
Came into force: 06.11.2006 (signed)
Taxation at source: did not come into force
Other taxation: did not come into force
Taxation of Republic of Kazakhstan: Corporate Income Tax, Personal Income Tax; Property Tax
Taxation of foreign countries: Corporate Income Tax, Personal Income Tax; Property Tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 01.03.2006
Taxation at source: Since 01.01.2007
Other taxation: Since 01.01.2007
Taxation of Republic of Kazakhstan: Corporate income tax; Personal income tax; Property tax
Taxation of foreign countries: Income tax; Corporate tax; Land tax; Tax on agricultural and forest enterprises
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 07.05.1997
Taxation at source: Since 01.01.98
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: tax on income and particular type of income of legal entities; individuals income tax; property tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 2%
Came into force: 13.12.1997
Taxation at source: Since 01.01.98
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: legal entities income and profit tax; income tax from citizens; real estate tax
Dividends: 15%
Interests: 10%
Royalties: 15%
Taxation of net income of permanent establishment: 5%
Came into force: 13.04.2000
Taxation at source: Since 01.01.00
Other taxation: Since 01.01.00
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: individuals income tax; corporate tax; legal entities income tax; non-residents income tax; additional deductions in case of crisis situations
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 24.07.1998
Taxation at source: Since 01.01.99
Other taxation: Since 01.01.99
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: total gain tax; profit tax; tax on building
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 30.03.1998
Taxation at source: Since 01.01.96
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: taxes collected by the Government of Canada under the law: Concerning Income Tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 09.08.2003
Taxation at source: Since 01.01.04
Other taxation: Since 01.01.04
Taxation of Republic of Kazakhstan: legal entities and individuals income tax
Taxation of foreign countries: Individuals income tax; Income tax from establishments with foreign investments and foreign establishments
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 29.10.1999
Taxation at source: Since 01.01.00
Other taxation: Since 01.01.00
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: individuals income tax; legal entities income tax; real estate tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 19.07.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax; local income tax
Dividends: 5%-15%
Interests: 10%
Royalties: 15%
Taxation of net income of permanent establishment: 5%
Came into force: 24.03.2009 (ratified by Republic of Kazakhstan)
Taxation at source: did not come into force
Other taxation:
did not come into force
Taxation of Republic of Kazakhstan:
Corporate Income Tax, Personal Income Tax
Taxation of foreign countries: "State income tax;
corporate income tax;
local rate;
church rate;
tax deducted at source with interests; and the tax deducted at source with non-resident income
"
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 01.08.2000 г.
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax; corporate tax; salary tax; joint property tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 05.07.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: establishment income and profit tax; individuals income tax; establishment property tax; individuals property tax
Dividends: 15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 21.12.1998
Taxation at source: Since 01.01.96
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax, tax on excess profit of users of mineral resources
Taxation of foreign countries: Income tax, corporate tax, property tax and tax on trade including extra charges
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 21.08.1996
Taxation at source: Since 01.01.93
Other taxation: Since 01.01.93
Taxation of Republic of Kazakhstan: income and profit tax
Taxation of foreign countries: income tax, corporate tax, capital gains tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5 % , if the amount of profit of the permanent establishment is more than 70'000 GBP
Came into force: 03.03.1996
Taxation at source: Since 01.01.97
Other taxation: Since 01.01.97
Taxation of Republic of Kazakhstan: establishment income and profit tax, individuals income tax, individuals property tax
Taxation of foreign countries: individuals profit tax, corporate tax, land property tax, construction tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 28.08.1997
Taxation at source: Since 01.01.98
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax; capital tax (wealth tax)
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 03.04.1999
Taxation at source: Since 01.01.00
Other taxation: Since 01.01.00
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: legal entities and individuals income tax, legal entities and individuals property tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 26.02.1997
Taxation at source: Since 01.01.94
Other taxation: Since 01.01.94
Taxation of Republic of Kazakhstan: income and profit tax
Taxation of foreign countries: personal income tax, corporate income tax, local income tax
Dividends: 5-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 30.11.2009 (ratified by Republic of Kazakhstan)
Taxation at source: did not come into force
Other taxation: did not come into force
Taxation of Republic of Kazakhstan: Corporate Income Tax, Personal Income Tax
Taxation of foreign countries: income tax;corporate tax; local taxes from population
Dividends: 5-15%
Interests: 10%
Royalties: 5%
Taxation of net income of permanent establishment: 15% according to Kazakhstani Tax Code
Came into force: 09.04.1999
Taxation at source: Since 01.01.00
Other taxation: Since 01.01.00
Taxation of Republic of Kazakhstan: legal entities and individuals income tax
Taxation of foreign countries: income tax;corporate tax; per capita tax ; special tax for the development of non-urban area
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 15% according to Kazakhstani Tax Code
Came into force: 31.03.1998
Taxation at source: Since 01.01.99
Other taxation: Since 01.01.99
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: legal entities income and profit tax; individuals income tax; individuals profit tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 02.12.2002
Taxation at source: Since 01.01.03
Other taxation: Since 01.01.03
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: Establishment income tax; Personal income tax; Property tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 11.12.1997
Taxation at source: Since 01.01.98
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: legal entities profit tax; individuals income tax; tax on establishment using the state capital; real estate tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 26.10.2009 (ratified by Republic of Kazakhstan)
Taxation at source: did not come into force
Other taxation: did not come into force
Taxation of Republic of Kazakhstan: "Corporate income tax; Personal Income Tax; Legal entities and Individuals Property tax
"
Taxation of foreign countries: "Individuals income tax;
corporate tax;
capital tax; and local trade tax"
Dividends: 5-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 22.02.2007
Taxation at source: Since 01.01.2008
Other taxation: Since 01.01.2009
Taxation of Republic of Kazakhstan: Corporate Income Tax, Personal Income Tax
Taxation of foreign countries: Income tax; Oil income tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 25.02.2002
Taxation at source: Since 01.01.03
Other taxation: Since 01.01.03
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax, property tax
Dividends: 10%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 02.12.1999
Taxation at source: Since 01.01.00
Other taxation: Since 01.01.99
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: Personal Income Tax, Corporate Income Tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 24.01.2006
Taxation at source: Since 01.03.2006
Other taxation: Since 01.01.2007
Taxation of Republic of Kazakhstan: Legal entities and Individuals Income Tax, legal entities and individuals property tax
Taxation of foreign countries: National income tax; district municipal income tax; municipal income tax; contributions to the National Fund of Tax equalisation; National capital tax; municipal capital tax; National tax relevant to income and capital gained from exploration-development of underseas oil resources , works and activities related to it, including transportation of oil products by oil line, National fees for actors-non-residents
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 29.01.1997
Taxation at source: Since 01.01.96
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax, overtax, additional tax "pakistan tax"
Dividends: 12,5%-15%
Interests: 12,5%
Royalties: 15%
Taxation of net income of permanent establishment: 15% according to Kazakhstani Tax Code
Came into force: 13.05.1995
Taxation at source: Since 01.07.95
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: establishment income and profit tax, individuals income tax, individuals property tax
Taxation of foreign countries: income tax of legal entity, income tax of individuals
Dividends: 10%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 21.04.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax
Taxation of foreign countries: individuals income tax; profit tax; wage and other compensation tax; agricultural activity income ta; tax on dividends; tax on buildings and land tax busy with buildings and constructions
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 15% according to Kazakhstani Tax Code
Came into force: 29.07.1997
Taxation at source: Since 01.01.98
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: tax on income (profit) of establishments and organizations; individuals income tax; tax on property of establishments; individuals property tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 14.08.2004
Taxation at source: Came into force on 14.08.2007 regulations are applied: a) In Kazakhstan: In relation to taxes for the tax period, starting on or after 1 January of calendar year, following after the year of coming into force of the Agreement; b) In Singapore: In relation to the tax subject to computation any year starting on or after 1 January of calendar year following after the year of coming into force of the Agreement;
Other taxation: Came into force on 14.08.2007 regulations are applied: a) In Kazakhstan: In relation to taxes for the tax period, starting on or after 1 January of calendar year, following after the year of coming into force of the Agreement; b) In Singapore: In relation to the tax subject to computation any year starting on or after 1 January of calendar year following after the year of coming into force of the Agreement;
Taxation of Republic of Kazakhstan: Corporate Income Tax, Personal Income Tax
Taxation of foreign countries: Income tax
Dividends: 5%-10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 30.12.2007 (ratified by Republic of Kazakhstan)
Taxation at source: Came into force on 28.07.2008 regulations are applied:
Other taxation: Came into force on 28.07.2008 regulations are applied:
Taxation of Republic of Kazakhstan: corporate income tax; personal income tax; property tax
Taxation of foreign countries: Individuals income tax; legal entities income tax; real estate tax;
Dividends: 10-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 02.10.1998
Taxation at source: Since 01.01.99
Other taxation: Since 01.01.99
Taxation of Republic of Kazakhstan: establishment income and profit tax, individuals income tax
Taxation of foreign countries: National income tax, including tax on sailors and tax on dividends, deducted at source; non-residents income tax; non-residents (actors and athlets) income tax; municipal income tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 24.11.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: Federal, cantonal local income tax (total gain, earned income, capital income, industrial and commercial activities profit, capital gains tax and other types of income); to the capital (joint property, personal and real estate, entrepreneurial property, the paid part of corporate capital and reserves and other types of capital);
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
However, if a profit of the permanent establishment for the current fiscal year doesn`t increase USD 100 000 this additional tax is not charged
Came into force: 07.11.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: legal entities income and profit tax; citizens income tax; legal entities and individuals property tax
Dividends: 10%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 27.04.1997
Taxation at source: Since 01.01.96
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income tax, salary tax, tax of company`s profit, dividends tax, capital tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 1) 0%, if the profit amount of the permanent establishment is not more than USD 100'000; 2) 5% - in other cases
Came into force: 15.11.1996
Taxation at source: Since 01.01.97
Other taxation: Since 01.01.97
Taxation of Republic of Kazakhstan: legal entities and individuals income tax
Taxation of foreign countries: income tax, corporate tax, duty deducted from income and corporate tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 10%
Came into force: 10.03.2000
Taxation at source: Since 01.01.01
Other taxation: Since 01.01.01
Taxation of Republic of Kazakhstan: legal entities and individuals income tax, legal entities and individuals property tax
Taxation of foreign countries: income and profit tax;individuals income tax; tax on use of subsoil; establishment property tax; land fee
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 07.04.1997
Taxation at source: Since 07.06.97
Other taxation: Since 01.01.97
Taxation of Republic of Kazakhstan: legal entities and individuals income tax
Taxation of foreign countries: establishment profit tax, citizens income tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 30.12.1996
Taxation at source: Since 01.02.97
Other taxation: Since 01.01.96
Taxation of Republic of Kazakhstan: income and profit tax
Taxation of foreign countries: Federal Income taxes which are charged in accordance with Internal Revenue Code , excluding of tax on accumulation of profits ,tax from personal holding companies and social insurance tax
Dividends: 5%-15%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 5%
Came into force: 21.04.1997
Taxation at source: Since 07.07.97
Other taxation: Since 01.01.98
Taxation of Republic of Kazakhstan: establishment income and profit tax, individuals income tax, individuals property tax
Taxation of foreign countries: establishments, incorporations, organizations income tax, Uzbekistan citizens income tax, foreign persons and stateless citizens, establishments property tax, individuals property tax
Dividends: 10%
Interests: 10%
Royalties: 10%
Taxation of net income of permanent establishment: 15% according to Kazakhstani Tax Code
Kazakhstan has an additional signed Double Tax Treaties with Spain, Armenia, Luxemburg, Slovakia, Finland and United Arabic Emirates, but not ratified yet.
In case there is no country you are interested in then it means that Kazakhstan has not concluded an agreement with the country concerned.
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