background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of a Contracting State, of a Land or of a political subdivision or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, the taxes on the total amounts of wages and salaries paid by enterprises, and taxes on capital appreciation.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) in the Republic of Kazakhstan:
    • (1) the tax on income of legal persons and individuals;
    • (2) the tax on the property of legal persons and individuals; and
    • (3) the tax on excess profit of users of natural resources;
  • (hereinafter referred to as "Kazakhstan tax");
  • (b) in the Federal Republic of Germany:
    • (1) the income tax (Einkommensteuer);
    • (2) the corporation tax (Körperschaftsteuer);
    • (3) the capital tax (Vermögensteuer); and
    • (4) the trade tax (Gewerbesteuer); including the supplements levied thereon,
  • (hereinafter referred to as "German tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.