Kazakhstan — Orbitax Country Chapters

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Kazakhstan — Orbitax Country Chapters

Table of Contents

ABOUT THE AUTHOR

1. FORMS OF DOING BUSINESS

1.1. Main Forms of Doing Business with a Legal Presence

1.1.1. Main Forms of Doing Business

1.1.1.1. Specific Uses of Available Legal Entities

1.1.1.2. Specific Constraints of Available Legal Entities

3. CORPORATE RESIDENCE

3.1. Corporate Tax Residence

3.2. Practical Aspects of Tax Residence

4. PERMANENT ESTABLISHMENTS

4.1. Foreign PE of a Domestic Entity

4.2. Domestic PE of a Foreign Entity

4.3. PE Force of Attraction Principle

4.4. Branch Profit (Deemed) Remittance Tax

4.5. PE Risk Grid for Foreign Entities Involved in Business Activities

5.1. Tax Base for Resident Entities

5.2. Treatment of Foreign Profits / Losses

5.3. Tax Consolidation / Group Treatment

5.4. Tax Base for Non-Resident Entities

5.5. Source Rules with Respect to Income Derived by Non-Residents

6. DETERMINATION OF TAXABLE INCOME

6.1. Main Rules Governing the Determination of Taxable Income

6.2. Depreciation and Amortization

6.3. Reserves and Provisions

6.4. Deduction of Cross-Border Payments and Non-Deductible Expenses

6.5. Excluded and Segregated Income

8.1.1. Other Taxes

8.2. Non-Residents

8.2.1. Corporate/Profit Taxes

8.2.2. Withholding Taxes

8.3. Exit Strategies

9. FOREIGN TAX CREDITS

10. INCENTIVES AND SPECIAL REGIMES

10.1. Holding Regimes

10.2. Financing Regimes

10.3. Intellectual Property Management Regimes

10.4. Specific Regimes

10.5. Incentives

10.6. Other Incentives

11. BUSINESS TRANSFORMATION AND RE-ORGANIZATION

11.1. Direct and Indirect Tax Consequences of Re-Organizations

11.2. Tax Consequence of Business Emigration, Corporate Inversions and the Cessation of Business

12. VAT ON INTERNATIONAL TRANSACTIONS

13. BASE PROTECTION AND ANTI-AVOIDANCE MEASURES

13.1. GAAR and General Anti-Avoidance Measures

13.2. Thin-capitalization and other Restrictions to Interest Deduction

13.3. CFC and Similar Regimes

13.4. Transfer Pricing

13.4.1. Main Rules

13.4.2. Specific TP Issues

13.4.3. Documentation Requirements

13.4.4. APAs and Dispute Resolution Mechanisms

13.5. Other Anti-Avoidance Rules

14. TAX MANAGEMENT AND COMPLIANCE

14.1. Books and Records

14.2. Type of Assessment

14.3. Calendar of Important Compliance Events

14.4. Tax Audits

14.5. Interest and Penalties

14.6. Interest Compensation for Overpayment of Tax

14.7. Appeal Procedures

15. TAX CONTROVERSIES

ABOUT THE AUTHOR

Written by Orbitax Research, our in-house team of international tax experts, with support from lo...