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Cyprus - Kazakhstan Double Tax Treaty

A double tax treaty with Kazakhstan was signed on 15 May 2019, the provisions of which will take effect on or after 1 January following the date the treaty enters into force.

Currently Kazakhstan levies withholding taxes of 15% on dividends, interest and royalties. Under the Cyprus – Kazakhstan double tax treaty the taxes that will be levied are as follows:-

  • Dividends – a 5% withholding tax is levied if the dividends are paid out to a foreign company which holds at least 10% of the share capital of the company paying the dividends.
  • Interest – a 10% withholding tax is levied on interest payments if the recipient is the beneficial owner of such interest.
  • Royalties - a 10% withholding tax is levied on royalty payments if the recipient is the beneficial owner of such royalties.
  • Capital gains – the gains derived by a resident of a contracting state from the alienation of shares or interest in the capital of a company which derives more than 50% of their value directly or indirectly from immovable property situated in that other contracting state, maybe taxed in that other contracting state, with the exception of gains derived from the alienation of shares listed on an approved stock exchange.

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