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On 30 December 2019, the President of Kazakhstan signed into Law the Cyprus – Kazakhstan Double Tax Treaty following its ratification by the Kazakh Parliament. The Treaty was previously ratified by Cyprus on 24 May 2019. On 17 January 2020 Cyprus and Kazakhstan finalised the exchange of written notifications, informing that the internal procedures required for the entry into force of the Treaty have been completed. As a result, the Treaty is now in force and shall have effect on 1st of January 2021.

Below is a summary of the main provisions of the Treaty.

Dividends

• Withholding tax at 5% on gross dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends;

• Withholding tax at 15% on gross dividends will apply in all other cases.

Interest

• Withholding tax on gross interest of 10% will apply.

Royalties

• Withholding tax on gross royalties of 10% will apply.

Capital Gains (Article 13)

Gains derived by a resident of a State from the alienation of shares or comparable interests in the capital of a company deriving more than 50% of their value directly or indirectly from immovable property situated in the other State may be taxed in that other State. This does not apply to gains derived from the alienation of shares of companies listed on an approved stock exchange. Any other disposal of shares is taxed in the State of the alienator.

Offshore Activities (Article 21)

Gains derived by an enterprise of a State from the alienation of shares or comparable interest deriving their value or the greater part of their value 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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