By the end of June of this year Kazakhstan signed the Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI).
The MLI is designed under the OECD-lead effort to help countries counter tax avoidance and speed cross-border of transnational tax dispute resolution.
It is expected that the MLI provisions will add to the existing bilateral double tax treaties (DTT) provisions agreed as a result of the base erosion and profit shifting plan. However, such amendments will be made only upon negotiation with each country party to the DTT. As was reported by the Minister of Finance of the Republic of Kazakhstan, Kazakhstan intends to apply the MLI provisions to 45 DTT’s.
The MLI provides for the following main changes:
‒ if the foreign legal entity proves that it is not a holding company, or
‒ if the participants of the foreign legal entity are deemed to be one of the following persons: resident individuals, non-commercial organisations, state authorities and companies which shares are traded on the recognized stock exchange;
About GRATA International
GRATA International is the largest independent Kazakhstani law firm, and one of the leading law firms in Central Asia and the Caspian Region. GRATA has provided a wide range of legal services in these regions for over 25 years.
Since its inception in 1992 the Firm has developed a very experienced Tax Practice. In 2005, the structure of the firm was fully established, featuring a specific department dealing with Tax Law. Unlike many consulting companies, GRATA’s tax team consists mainly of lawyers and auditors, who have experience working with the tax authorities. This distinct perspective enables us to provide our clients with correct and practical advice.
• Representation and Protection of Client's Interests in Tax Disputes;
• VAT Refund from the Budget;
• Support in Tax Audits;
• Taxation of Subsoil Users;
• International Taxation;
• Finance Taxation (securities, financial instruments, loan agreements);
• Corporate Taxation and Tax Planning;
• Individual Taxation;
• Tax Support and Structuring in M&A Transactions;
• Due Diligence of Tax Accounting (Tax Audit);
• Tax Administration.
For additional information, please visit www.gratanet.com, or contact:
Head of Tax Department
+7 (727) 2445-777
+7 (701) 763-07-14
This alert for informational purposes only and shall not be recognized as legal advice. GRATA International is not responsible for any consequences arising from the use of the aforementioned information without its consent.
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