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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Kazakhstan: interest

Interest arising in Kazakhstan and paid to a resident of the United Kingdom who is the beneficial owner of the interest is taxable in Kazakhstan at a rate not exceeding 10 per cent (Article 11(2)), except where the interest is effectively connected with a permanent establishment or fixed base which the UK resident recipient has in Kazakhstan. In the latter circumstances the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.

Where Kazakhstan source interest is paid to a United Kingdom resident who is the beneficial owner of the interest, in respect of a loan made, guaranteed or insured by the United Kingdom Export Credits Guarantee Department, it is exempted from Kazakhstan tax (Article 11(11)).

With effect from 1 January 1999, interest paid by the Government of Kazakhstan or by a local authority of Kazakhstan is exempted from Kazakhstan tax (Article 11(10)).