From January 1st 2020 it is expected to take into force the new DTT singed between Cyprus and Kazakhstan. The agreement was signed and ratified on the 15th of May 2019 and is expected to provide new investment opportunities and better protection to tax residents of the two countries.
Below we summarize the benefits of the treaty for your information:
- 5% withholding tax provided that 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.
- 15% withholding tax in all other cases.
- 10% withholding tax on interest payments, if the recipient is the beneficial owner of such interest.
- 10% withholding tax is taxable on royalty payments provided that the recipient is the beneficial owner of such royalties.
Gains derived by a resident of a Contracting State from the alienation of shares or similar interests in the capital of a company deriving more than 50 per cent (50%) of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other Contracting State.
The above does not apply to gains derived from alienation of shares listed on an approved stock exchange.