{"id":6782,"date":"2019-07-16T09:37:08","date_gmt":"2019-07-16T06:37:08","guid":{"rendered":"https:\/\/vrikislegal.com\/?p=6782"},"modified":"2019-07-16T09:38:05","modified_gmt":"2019-07-16T06:38:05","slug":"cyprus-double-tax-treaty-with-the-republic-of-kazakhstan","status":"publish","type":"post","link":"https:\/\/www.vrikislegal.com\/sv\/cyprus-double-tax-treaty-with-the-republic-of-kazakhstan\/","title":{"rendered":"Cyprus \u2013 Double Tax Treaty with the Republic of Kazakhstan"},"content":{"rendered":"

Cyprus is continuing its ongoing efforts to increase its global network of Double Tax Treaties and in this respect Cyprus and Kazakhstan have, on 15 May 2019, signed a Double Tax Treaty (the \u201cDTT<\/strong>\u201d) aiming to enhance the economic and trade relations between the two states, while bringing new opportunities and better protection for taxpayers in both states.<\/p>\n

The DTT has been ratified by Cyprus on 24 May 2019 and it is expected to become effective on or after 1 January 2020.<\/p>\n

The DTT is generally based on the OECD Model Double Tax Convention framework.<\/p>\n

The main provisions of the DTT are briefly outlined below:<\/p>\n

(a) There shall be a maximum of 5% withholding tax on dividend payments if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends.<\/p>\n

(b) In all other cases, there shall be a maximum of 15% withholding tax.<\/p>\n

(a) There shall be a maximum of 10% withholding tax on interest payments if the recipient of the interest is the beneficial owner of such income.<\/p>\n

(b)\u00a0There shall be 0% withholding tax on interest payments if the beneficial owner of the interest is the Government of the other contracting state, or a political subdivision, a central or local authority, the Central Bank or any other financial institution wholly owned by the Government of the other contracting state.<\/p>\n

There shall be a maximum of 10% withholding tax on royalty payments, if the recipient of the royalties is the beneficial owner of such income.<\/p>\n

With respect to capital gains, Cyprus retains the exclusive taxing right on the disposal of shares made by Cyprus tax residents, except in the following cases:<\/p>\n

(a) Where the shares (other than shares listed on an approved stock exchange) derive more than 50% of their value directly or indirectly from immovable property situated in Kazakhstan; or<\/p>\n

(b) Where the shares derive the greater part of their value from certain offshore rights and\/or movable property relating to the exploration or exploitation of the seabed or subsoil or their natural resources located in Kazakhstan.<\/p>\n","protected":false},"excerpt":{"rendered":"

Cyprus is continuing its ongoing efforts to increase its global network of Double Tax Treaties and in this respect Cyprus and Kazakhstan have, on 15 May 2019, signed a Double Tax Treaty (the \u201cDTT\u201d) aiming to enhance the economic and trade relations between the two states, while bringing new opportunities and better protection for taxpayers […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[18,96],"tags":[19,14],"class_list":["post-6782","post","type-post","status-publish","format-standard","hentry","category-news","category-tax-updates","tag-news","tag-tax"],"_links":{"self":[{"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/posts\/6782","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/comments?post=6782"}],"version-history":[{"count":0,"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/posts\/6782\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/media?parent=6782"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/categories?post=6782"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.vrikislegal.com\/sv\/wp-json\/wp\/v2\/tags?post=6782"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}