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International Taxation
International Taxation 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 specialists can provide clear answers. We
consult on issues of the permanent establishment of non-residents, tax
optimisation of income of non-residents from sources in Kazakhstan,
corporate structure and structure of transactions from a tax
perspective, and refunds of income tax and the opening of conditional
bank deposits. Recent Experience:- providing
recommendations for organizing a more effective corporate structure for a major
shipping company so as to minimize
the taxation of income from shipping
activities;
- advising international
financial institutes about the taxation of transactions, connected with
payments of international loans, guarantees and leasing agreements;
- providing
recommendations for international investment groups on how to achieve a more
effective corporate structure for entrepreneurial activities in Kazakhstan and
abroad in the context of taxation;
- consultation of
banks, service, trade, engineering and other companies concerning formation of
permanent establishment in Kazakhstan;
- providing
consultations to the owner of a major internet company regarding
taxation of income resulting from transfer of exclusive rights to the
website;
- consulting of the
world's largest food producer with regard to taxation in Kazakhstan of
royalties paid to non-residents;
- advised
a Kazakh airline company on the tax implications of conducting an agreement on
the operational lease of an aircraft;
- providing
consultations to a leading European bank on tax issues for Eurobonds, as well
as potential tax risks;
- providing
consultations to an uranium company on the tax treatment of interest and other
payments under a loan agreement and the potential tax risks associated with the
condition of a ‘gross-up’ clause;
- providing
consultation to the leading European
aerospace company on tax issues involved in providing services to the
Kazakhstan National Company for the design, installation and testing of
aerospace equipment;
- advised on the
taxation of income earned by non-residents from management, consulting
services, services to provide personnel, and the application of conventions on
the avoidance of double taxation; analysis of the risks of creating a permanent
establishment in Kazakhstan and obligations to pay VAT for a non-resident;
- advised major
telecommunications companies on the legal consequences of debt restructuring.
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