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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Kazakhstan: non-discrimination

Kazakhstan was entitled under the terms of the agreement to continue until 1 January 1998 to charge the 5 per cent rate differential which, at the time of entry into force of the Agreement, existed in Kazakhstan law between the taxes imposed on residents of the United Kingdom and enterprises of Kazakhstan. After 1 January 1998, the taxes imposed on residents of the UK under the laws of Kazakhstan are charged at the same rate as the taxes imposed on Kazakhstan enterprises.

However, from 1 January 1999, where a United Kingdom company trades in Kazakhstan through a permanent establishment there and the year’s profits attributable to that permanent establishment exceed £70,000, those profits may be subjected to an additional Kazakhstan tax not exceeding 5 per cent of those profits.