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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Kazakhstan: source of income

For the purposes of the Elimination of double taxation Article, profits, income or capital gains owned by a resident of the United Kingdom which may be taxed in Kazakhstan under the provisions of the agreement are deemed to be profits, income or capital gains from sources in Kazakhstan (Article 22(3)).

Interest is usually deemed to arise in the State in which the payer is resident, including where the payer is the State itself or a political subdivision or local authority thereof. The exception is where the person paying the interest, has, in one of the countries, a permanent establishment or fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by that permanent establishment or fixed base. In such a case the interest is deemed to arise in the State in which the permanent establishment or fixed base is situated (Article 11(5)).