[Provisional translation]
[Attachment]
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(1) Clarification of taxable scope in the partner country where enterprises carry on businesses
If a Japanese company establishes a permanent establishment (branch offices, etc.) and conducts business activities in the Republic of Kazakhstan, only business profits resulting from business activities carried out through the permanent establishment is to be subject to tax in the Republic of Kazakhstan. -
(2) Maximum tax rate for Investment Income (Dividends, Interest and Royalties) in the source country
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(1) Dividends (Article 10)
The maximum tax rate for dividends in the source country is stipulated as below:-
(i) Between parent and subsidiary companies (Shareholding ratio: at least 10%) : 5%
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(ii) Others: 15%
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(2) Interest (Article 11)
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(i) The maximum tax rate for interest in the source country is 10%.
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(ii) Interest received by specific governmental institution is to be exempted from taxes in the source country.
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(3) Royalties (Article 12)
The maximum tax rate for royalties in the source country is 10%.-
(Note) The maximum tax rate is substantially reduced to 5% in the Protocol.
(Reference)
- ”Source country” means a country where the income arises.
- ”Maximum tax rate” means the upper limit of taxation (a tax rate) in the source country.
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(3) Others
In line with the provisions of recent international model tax convention and our country’s tax convention with other countries, following provisions, in addition to the above, are stipulated:-
(i) Mutual Agreement Procedure between tax authorities (Article 24)
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(ii) Exchange of Information on taxes between the tax authorities (Article 25)
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