Taxation of non-residents

The complexity of International Tax Law, including the Convention on the Avoidance of Double Taxation, and peculiarities in the taxation of non-residents in Kazakhstan, raise many questions for which GRATA International specialists can provide clear answers.

We are glad to advise on the following issues:

• advising on taxation of non-resident’s income from source of payment;

• advising on application of rules of ‘controlled foreign companies’;
  
• advising on permanent establishment risk;
  
• tax optimization of non-resident’s income from sources in Kazakhstan;
  
• choosing the most suitable form (legal entity or structural subdivision) for certain business type for taxation purposes;
  
• corporate structure and transaction structure from tax law perspective.