Income Tax Treaty between the United States and Kazakhstan

 

United States-Kazakhstan Tax Treaty

Kazakhstan International Tax Compliance Rules

Quick Summary.  Located in the north of Central Asia, Kazakhstan borders Russia, China, Kyrgyzstan and Uzbekistan, as well as the Caspian Sea and Turkmenistan.  Kazakhstan is the largest landlocked country in the world and boasts significant mineral resources.  The country is comprised of 14 administrative zones and covers an area of 2.724 million square kilometers.  

Kazakhstan obtained independence in 1991.  Kazakhstan is a unitary state, and a constitutional republic with a bicameral Parliament (the Parliament of the Republic of Kazakhstan) consisting of a Senate and Mazhilis chamber.   The President of the Republic of Kazakhstan is the head of state.  The government, ministries, and local executive administrations in the regions (“Akimats”) are empowered to issue regulations and executive acts within the confines of law.  The court system is headed by a Supreme Court of the Republic and Constitutional Council.  

Kazakhstan is part of the Eurasian Economic Union, and EAEU regulations and decisions supersede the national regulatory system.  Kazakhstanis a member of the World Trade Organization (WTO).

Tax Code applies taxes universally and applies an international model of taxation, based on the principles of equity, economic neutrality, and simplicity.

U.S-Kazakhstan Tax Treaty

Kazakhstan Tax Treaty.  Convention between the Government of the United States of America and the Government of the Republic of Kazakhstan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, together with the Protocol and two related exchanges of notes, signed at Almaty on October 24, 1993

Currency.  Kazakhstan Tenge (KZT)

Common Legal Entities.  Joint stock company, limited liability company, unregistered partnership (consortium), and branches.  

Tax Authorities.  State Revenue Committee of the Ministry of Finance

Tax Treaties.  Kazakhstan is party to 54 tax treaties.  

Corporate Income Tax Rate.  20%

Individual Tax Rate.  15%.  

Corporate Capital Gains Tax Rate.  Taxed at ordinary income rates.  

Individual Capital Gains Tax Rate.  5% – 15%.  

Residence.  Individual tax residents are defined as individuals permanently residing in Kazakhstan or having a centre of vital interests in Kazakhstan.  

Withholding Tax.

            Dividends. 15% generally.  

            Interest.   15% generally. 

            Royalties.  15% generally. 

Excess Profit Tax.  Rates range from 10% to 60%.  

Transfer Pricing.  Applies an arm’s-length standard; however, the standard differs from OECD transfer pricing guidelines.  

CFC Rules.  Yes.  

Inheritance/estate tax.  No.  

Tax Treaty Network – International Tax Attorneys

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