Double tax treaties concluded by Kazakhstan

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