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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Kazakhstan: Dividends

The Kazakhstan tax deducted from dividends at the agreement rate of 15 per cent (5 per cent if the recipient is a United Kingdom company which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)).

This reduced rate does not apply if the dividends are effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on through a permanent establishment or fixed base which the recipient has in Kazakhstan.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Kazakhstan company paying the dividend is entitled, under Article 22(1)(b), to credit for underlying tax (see INTM164010(d)).