A new Double Tax Treaty was signed on 15 May 2019 between Cyprus and Kazakhstan. The Treaty, which was published in the Gazette on 24 May 2019, will enter into force as soon as the ratification process is completed by both countries, and its provisions are expected to be applicable on 1 January of the following year.
The Treaty is based on the OECD Model Convention and thus incorporates the latest international standards with regards to exchange of information, mutual agreement procedure, and as well as a principal purpose test.
This new Treaty is expected to enhance the commercial and economic relationships between the two countries and to provide opportunities for further cooperation.
The main provisions of the Treaty are as follows:
NOTE: As per the local Cyprus legislation, Cyprus does not withhold tax on outbound dividends or interest payments, and only withholds tax on royalty payments (10%) if the royalties are used within Cyprus.