Amendments have been made to the terms of application of international agreements for the payment of passive income to non-residents (dividends, royalties). This was reported in the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan.

Since January 1, 2021, the Republic of Kazakhstan has a Multilateral convention on the implementation of measures related to tax agreements in order to counteract the erosion of the tax base and the withdrawal of profits from taxation.

The purpose of the multilateral convention is to exclude non-taxation or reduced taxation by avoiding or evading taxes.

Amendments to Article 667 of the Code of the Republic of Kazakhstan "On Taxes and other mandatory payments to the Budget" presupposes additional conditions for the application of bilateral Tax agreements by a tax agent (the amendments entered into force on 01.01.2023).

At the same time, according to paragraph 5 of Article 4 of the Tax Code, if an international treaty ratified by the Republic of Kazakhstan establishes other rules other than those contained in the Tax Code, the rules of the specified agreement apply.

In connection with the above, amendments to Article 667 of the Tax Code will be applied in strict accordance with the provisions of international treaties.

Work on further improvement of international taxation will continue.