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Cyprus – Kazakhstan Double Tax Treaty

  • June 23, 2020
  • Posted by: Elias Christofi & Co Ltd
  • Category: Corporate & Fiduciary Services
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Another double tax treaty! Cyprus and Kazakhstan signed a Double Tax Treaty in December 2019.  The treaty will come into full effect on the 1st of January 2021.

 

The main provisions of the treaty are as follows:

 
  • 10% withholding tax on gross interest
  • 0% withholding tax on interest payments where the beneficial owner of the interest is the Central Bank or any other governmental institution.
  • 10% withholding tax on gross royalties
  • 5% withholding tax on gross dividends (*if the beneficial owner is a company and holds directly at least 10% of shares of the company paying the dividends). In all other cases there will be 15% withholding tax on gross dividends.
  • Capital Gains derived from the disposal of shares which include immovable property, disposed by a resident of either Cyprus or Kazakhstan and deriving more than 50% of their value from immovable property situated in the other State, the Capital gain may be taxed in that other State. Any other disposal of shares is taxed in the State in which its resident is disposing the shares. The above does not apply to gains derived from the disposal of shares listed on an approved stock exchange.
  • Gains derived by a company from offshore activities in either Cyprus or Kazakhstan, from the disposal of shares and of which their derived value or the greater part of their value derives directly or indirectly from exploration or exploitation rights and/or movable property situated in the other State and used in connection with offshore activities carried on in that other State may be taxed in that other State.

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