Below is the list of jurisdictions with which Kazakhstan has signed double taxation treaties. The list was updated in March 2018. In mid-2018 Kazakhstan has singed a double tax treaty with Cyprus (not yet listed).
Most of tax treaties, according to the Ministry of Finance of the Republic of Kazakhstan, are based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital (OECD MTC) and some of the tax treaties are based on the UN Model Double Taxation Convention (UN MTC). The tax treaty with the US is based on the US Model Income Tax Convention, nevertheless, the text of the Kazakhstan-US DTT contains number of deviations towards the UN MTC.
The list contains jurisdictions and applicable withholding tax rates on dividends, interest and royalty.
No | State | Dividends | Interest | Royalty | Capital gain | Other income |
1 | Armenia | 10% | 10% | 10% | does include shares if 50% of underlying assets is property | taxed in the state of the beneficiary |
2 | Austria | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does not include shares | taxed in the state of the beneficiary |
3 | Azerbaijan | 10% | 10% | 10% | does not include shares | may be taxed in the source state |
4 | Belarus | 15% | 10% | 15% | does not include shares | taxed in the state of the beneficiary |
5 | Belgium | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
6 | Bulgaria | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
7 | Canada | 5% (not less than 10% holding) & 10% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | may be taxed in the source state |
8 | China | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
9 | Czech Republic | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
10 | Estonia | 5% (not less than 25% holding) & 15% in other cases | 10% | 15% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
11 | Finland | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if 50% of underlying assets is property | taxed in the state of the beneficiary |
12 | France | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
13 | Georgia | 15% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
14 | Germany | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
15 | Hungary | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
16 | India | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
17 | Iran | 5% (not less than 20% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | may be taxed in the source state |
18 | Ireland | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if 50% of underlying assets is property | taxed in the state of the beneficiary |
19 | Italy | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does not include shares | taxed in the state of the beneficiary |
20 | Japan | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of the beneficiary |
21 | Korea (South) | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority (75% or more) of underlying assets is property | taxed in the state of the beneficiary |
22 | Kyrgyzstan | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
23 | Latvia | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
24 | Lithuania | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
25 | Luxembourg | 5% (not less than 15% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
26 | Macedonia | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of the beneficiary |
27 | Malaysia | 10% | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | may be taxed in the source state |
28 | Moldova | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
29 | Mongolia | 10% | 10% | 10% | does not include shares | taxed in the state of source |
30 | Netherlands | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
31 | Norway | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
32 | Pakistan | 12,5% (not less than 10% holding) & 15% in other cases | 12,5% | 15% | does include shares if majority of underlying assets is property | taxed in the state of source |
33 | Poland | 10% (not less than 20% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of source |
34 | Qatar | 5% (not less than 10% holding) & 10% in other cases | 10% | 10% | does not include shares | taxed in the state of the beneficiary |
35 | Romania | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of source |
36 | Russia | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
37 | Saudi Arabia | 5% | 10% | 10% | does include shares | taxed in the state of the beneficiary |
38 | Serbia | 10% (not less than 25% holding) & 10% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of the beneficiary |
39 | Singapore | 5% (not less than 25% holding) & 10% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of source |
40 | Slovakia | 10% (not less than 30% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
41 | Slovenia | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of the beneficiary |
42 | Spain | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority (50% or more) of underlying assets is property | taxed in the state of the beneficiary |
43 | Sweden | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
44 | Switzerland | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
45 | Tadjikistan | 10% (not less than 30% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
46 | Turkey | 10% | 10% | 10% | does not include shares | taxed in the state of the beneficiary |
47 | Turkmenistan | 10% | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
48 | UAE | 5% (not less than 10% holding) | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
49 | UK | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
50 | Ukrain | 5% (not less than 25% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of the beneficiary |
51 | USA | 5% (not less than 10% holding) & 15% in other cases | 10% | 10% | does include shares if majority of underlying assets is property | taxed in the state of source |
52 | Uzbekistan | 10% | 10% | 10% | does not include shares | taxed in the state of the beneficiary |
53 | Vietnam | 5% (not less than 70% holding) & 15% in other cases | 10% | 10% | does include shares if majority (30% or more) of underlying assets is property | taxed in the state of the beneficiary |