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HMRC internal manual

Double Taxation Relief Manual

DT:Kazakhstan: double taxation agreement, Article 23: Limitation of relief

  1. Where under any provision of this Convention any income is relieved from tax in a Contracting State and, under the law in force in the other Contracting State a person, in respect of that income, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first mentioned Contracting State shall apply only to so much of the income as is taxed in the other Contracting State.
  2. Notwithstanding the provisions of any other Article of this Convention, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that Contracting State, on income or capital gains shall not receive the benefit of any reduction in or exemption from tax provided for in this Convention if the main purpose or one of the main purposes of such resident was to obtain the benefits of this Convention.