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Kazakhstan-OECD

1 December 2020

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Kazakhstan Updates MLI Position

The OECD has published an updated (consolidated) MLI position deposited by Kazakhstan on 26 November 2020. The consolidated MLI position includes:

  • Corrections to the entry into force dates provided in the original MLI position for certain tax treaties and treaty protocols, including those with Azerbaijan, Belarus, China, Croatia, India, Ireland, Qatar, Ukraine, and Uzbekistan;
  • Additional notification regarding the preamble language for the tax treaties with the Czech Republic, France, Germany, Luxembourg, Russia, and Uzbekistan;
  • Corrections to the referenced articles in certain tax treaties in relation to the prevention of treaty abuse, including the treaties with Poland, Sweden, and the UK, as well as the addition of article references for the treaties with Armenia, Azerbaijan, Estonia, Germany, India, Russia, and Spain;
  • A correction to the referenced article for the tax treaty with the Netherlands in relation to MLI Article 8, which requires minimum ownership requirements to be met for throughout a 365-day period including the date of payment;
  • A correction to the referenced article for the tax treaty with Vietnam and additional notification on reference articles for the tax treaties with China and Switzerland in relation to MLI Article 9, which provides for the taxation of gains from the alienation of share deriving value from immovable property where a value threshold is met at any time during the 365 days preceding the alienation;
  • Corrections to the referenced articles for the tax treaties with Georgia, Malaysia, Mongolia, Turkmenistan, and Vietnam in relation to MLI Article 12 on artificial avoidance of permanent establishment status through commissionnaire arrangements and similar strategies
  • A correction to the reference articles for the tax treaty with the Netherlands in relation to MLI Article 13 on artificial avoidance of permanent establishment status through the specific activity exemptions;
  • Additional notification regarding MLI Article 14 on splitting-up of contracts for the tax treaties with the Czech Republic, Ireland, Latvia, Lithuania, the Netherlands, Norway, and Serbia;
  • Additional notifications regarding the relevant MAP articles in all covered tax treaties in relation to MLI Article 16 on the presentation of cases to competent authorities of either Contracting State;
  • The removal of the treaty with Poland as a treaty without a provision described in MLI Article 16(4)(c)(i), which concerns the competent authorities endeavoring to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the covered tax treaty; and
  • The removal of the tax treaties with Azerbaijan, Georgia, Kyrgyzstan, and Ukraine as treaties that already contain corresponding adjustments provisions that are replaced in line with MLI Article 17, as well as the addition of the tax treaties with India and Italy as already containing such provisions.

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