articles | 21 June 2019 | ServPRO

Cyprus tax update: Cyprus – Kazakhstan DTT

On 24 May 2019, Cyprus ratified the double taxation treaty it had signed with Kazakhstan earlier this year which is expected to enter into force on the 1st of January following the year that all steps are taken by the two countries to give effect to the treaty.

The key provisions of the agreement are summarised below:

• 5% withholding tax on dividend payments where the recipient is a company (other than partnership) that directly holds at least 10% of the capital of the paying company. In all other cased a 15% withholding tax applies. • 10% withholding tax on interest payments. In cases where the beneficial owner of the interest is the Government or a body as per article 11(3) of the DTT then a 0% withholding tax applies. • 10% withholding tax on royalty payments • Capital gains – Cyprus retains the exclusive taxing rights on disposals of shares made by Cyprus tax residents, except in cases where a) there are non-listed shares which derive more than 50% of their value, directly or indirectly, from immovable property situated in Kazakhstan, and b) shares which derive the greater part of their value from certain offshore rights and/or movable property relating to exploration or exploitation of the seabed or subsoil or their natural resources located in Kazakhstan. • The DTT also in incorporated the Principal Purpose Test of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project Action 6 which provides that a DTT benefit shall not be granted if obtaining that benefit was one of the principal purposes of an arrangement or transaction. For further information and advice please do not hesitate to contact our experienced professionals.

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