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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT:Kazakhstan: double taxation agreement, Article 2: Taxes covered

  1. This Convention shall apply to taxes on income and on capital gains imposed on behalf of a Contracting State irrespective of the manner in which they are levied.

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

  3. The taxes which are the subject of this Convention are:

(a) in the case of the United Kingdom:

(i) the income tax;

(ii) the corporation tax; and

(iii) the capital gains tax
(hereinafter referred to as “United Kingdom tax”);

(b) in the case of the Republic of Kazakhstan, the taxes on income and profits enacted in the following laws:

(i) the law “On the Taxation of Enterprises, Associations and Organisations”; and

(ii) the law “On the Income Tax on Citizens of the Republic of Kazakhstan, Foreign Citizens and Stateless Persons”
(hereinafter referred to as “Kazakhstan tax”).

  1. This Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Convention in addition to, or in place of, the taxes of that Contracting State referred to in paragraph (3) of this Article. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.