The double tax treaty between Cyprus and Kazakhstan was signed in Nursultan, Kazakhstan on 15th of May 2019 (the “Treaty”).
The Treaty is based on the OECD Model Tax Convention, a model for countries concluding bilateral tax treaties, aiming in removing tax related barriers to cross border trade and investment by implementing provisions for the avoidance of double taxation on income and capital gains tax.
Main Provisions of the Treaty:
1. Dividend Income
If the ultimate beneficial owner of a company is a company – not a partnership (as defined under Cyprus law), and holds a direct shareholding of at least 10% of the iss...