KazaKhstan

Aequitas

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KAZAKHSTAN KAZAKHSTAN KAZAKHSTAN KAZAKHSTAN

47 Abai Avenue, Office 2

Almaty, 050000

Tel: +7 (727) 396-8968

Fax: +7 (727) 396-8990

2 Zheltoksan, Office 19

Astana, 010000

Tel/Fax: +7 (7172) 323-778

27 Momysh-Uly Str., Office 8

Atyrau, 060000

Tel/Fax: +7 (7122) 586-110

www.aequitas.kz

KAZAKHSTAN: TAX COMPASS 2011

Corporate income taxation
Corporate Tax up to 20%

Dividends (for resident companies)

N/A for certain types of shares funds

0%

Capital gain exemptions (for resident companies)

N/A for certain types of capital gains sources		 0%
Deduction of Interests up to 100%
Thin Capitalization Rule

Based on proportion (ratio) of Equity Capital

 Yes
Depreciation
  • Accelerated depreciation (for certain assets)
Linear/Nonlinear
Yes

Transfer Pricing Rules                                   
Methods: Comparable Market Prices; Resale Price; Cost plus; Net Margin Method; Profit Split Method

  • APA available
Yes
Loss carried forward
Loss carried backward
10 years
N/A
Fiscal unity/Tax consolidation N/A
Withholding taxation

Dividends

  • Participation Exemption (for individuals and non-resident companies):
    • if holding duration is more than 3 years; and
    • the dividend payer is not a subsoil user in Kazakhstan; and
    • at least 50% of the value of the shares in the dividend payer derives from the value of the property owned by an entity which is not a subsoil user in Kazakhstan
  • Listing Exemption (for individuals and non-resident companies):
    • if the dividend payer is listed at the official list of the stock exchange in Kazakhstan on the date of distribution of dividends

 

15%
0%

 

 

 

 

 

0%

Capital gains (for non-resident companies)

  • Shares Sale Exemption (applicable to sale of the shares, except for the shares which value on at least 50% derives from the value of the property owned by an entity which is a subsoil user in Kazakhstan)
  • Listed Securities Sale Exemption (applicable to the listed securities sold via the open trade at any stock exchange)
 15%
0%


0%

Withholding Tax

 5% - 20%

Interests and royalties

15%

Double Tax Treaty Network (over 40 DDTs): reduction /elimination of WTH taxation
Personal Income tax
General flat rate 10%

Dividends
Exemptions are under the same rules as for dividends in “Withholding taxation” section above

 5%
0%
Inheritance tax N/A
Real Estate Transfer Taxes / Duty N/A
Value Added Tax

Standard rate           

  • Not applicable if annual revenue < KZT 45.4  Mio (approx. EUR 220,000)
  • Exemption available for certain products and services
  • Reverse Charge Method is available for some cases
 12 %
Property taxation

Corporations
(depending on the payer)

 0% - 1.5 %

Land Tax

Calculated depending on the type (designation) and quality of land
Severance Tax

On extracted minerals: gas, oil, minerals etc.
Excises

On alcohol, tobacco, petroleum etc.
Social Security Contributions
Payable by the employers only 11%
Incentives for Investors

Income and property tax exemption in Special Economic Areas
Investment tax preference (e.g. deduction of 100% of value of certain assets)
Special (simplified) tax regime

Available for small businesses / individual entrepreneurs
Advance (binding) tax rulings N/A
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