Kazakhstan

Convention between Kazakhstan and Ukraine for the avoidance of double taxation dated 9 July 1996 entered into force on 14 April 1997 (ratified by the Law of Ukraine # 508 dated 15 November 1996).

Article 10 (Dividends):

Paragraph 2. Dividends may be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:

(a) 5 % of the gross amount of the dividends if the beneficial owner is a company and this company holds at least 25% of the capital of the company paying the dividends;

(b) 15 % of the gross amount of the dividends in all other cases.

Article 11 (Interest):

Paragraph 2. Interest may be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10 % of the gross amount of the interest.

Paragraph 8. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State shall be exempt from tax in that State if it is received and really held by the Government of the other Contracting State, its political-administrative subdivision or its local authority, or any agency created or governed by that Government, political-administrative subdivision or local authority.

Article 12 (Royalties):

Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and according to the laws of that State, but the tax so charged shall not exceed 10 % of the gross amount of the royalties.


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