Double Tax Treaty between Cyprus and Republic of Kazakhstan


Double Tax Treaty between Cyprus and Republic of Kazakhstan


On May 30th, 2018, the successful final round of negotiation within the conclusion of the negotiation of the Convention for the Avoidance of Double Taxation and the Prevention of Tax Evasion on Income Taxes between the Republic of Cyprus and the Republic of Kazakhstan, took place. The agreed text was the result of intensive negotiations lasted one year.

               On 24 May 2019, Cyprus ratified the said double tax treaty which it had signed with Kazakhstan (the “DTT”).

The DTT is ‘in effect’ as from January 2020.

               We set out below an overview of selected provisions of the DTT:



                A maximum 10% WHT rate on interest payments. For certain interest payments to the Government the DTT provides for a 0% WHT rate.




               A maximum 5% withholding tax (WHT) rate applies on dividend payments where the recipient is a company (other than partnership) that directly holds at least 10% of the capital of the paying company. For other cases, the DTT provides for a maximum 15% WHT rate on dividends.



               A maximum 10% WHT rate in the case of royalty payments. Royalty payments are in consideration for: the use of, or the right to use, any copyright of literary, artistic or scientific work, software, including cinematograph films, tapes for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information (know how) concerning industrial, commercial or scientific experience and payments for the use of, or the right to use, industrial commercial or scientific equipment.

               Royalty payments do not include payments for the use of, or the right to use, ships or aircrafts.


Capital gains

               For capital gains Cyprus retains the exclusive taxing rights on disposals of shares made by Cyprus tax residents, except in the following cases:

• non-listed shares which derive more than 50% of their value, directly or indirectly, from immovable property situated in Kazakhstan, and,

• shares which derive the greater part of their value from certain offshore rights and/or movable property relating to exploration or exploitation of the seabed or subsoil or their natural resources located in Kazakhstan.


              *We note that irrespective of 5% or 15% WHT rates provided for in the DTT applicable to dividend payments, 10% WHT applicable on interest payments and 10% WHT rate on royalty payment NO Cyprus WHT applies on interest payments, dividends and royalties (except in the case of royalty payments earned on rights used within Cyprus) to non-Cyprus tax residents.





For further information on this topic please contact

Mrs. Liza Bokova( ) at SOTERIS PITTAS & CO LLC,

by telephone (+357 25 028460) or by fax (+357 25 028461)



The content of this article is intended to provide a general guide to the subject matter. Specialist advise should be sought about your specific circumstances.


Thursday, 07 September 2023 11:56

In a recent decision, the Court recognized its power to appoint a Receiver by a way of equitable execution of a judgment.   The case concerned an Application to extend the powers of the Interim...

Wednesday, 28 June 2023 09:47

In a recent case, handled by our law firm, on behalf of a judgment creditor, the District Court of Limassol, upon the application of the judgment creditor – (and after a contested hearing) – issued...

Tuesday, 06 June 2023 11:03

In a very recent case concerning an application for registration, recognition and enforcement of a Partial Final LCIA Arbitral Award in Cyprus, the Cypriot court was called to examine whether the...

Tuesday, 09 May 2023 09:51

In the very recent decision of Re Mosaica Investments Limited, Petition No. 573/2022 DC. Nicosia, Interim Decision dated 21.02.2023, the Cypriot Court, by following relevant English and Cypriot...

Tuesday, 20 December 2022 16:16

    In a recent decision of the District Court of Limassol in the context of an action filed by a foreign entity against local Banks, regarding the request of the Applicant for disclosure of...

Monday, 28 November 2022 09:06

    On 22 November 2022, the European Court of Justice held that the general public’s access to information on beneficial ownership constitutes a serious interference with the fundamental rights...

Friday, 24 June 2022 09:22

  CYPRUS: Can English Schemes of Arrangements sanctioned pursuant to the UK Companies Act 2006 be recognized and enforced in Cyprus or create any legal effects in Cyprus?   It is indisputable...

Thursday, 02 June 2022 13:19

  Cyprus Funds eligible as Foreign Portfolio Investors in India   The Minister of Finance of India decided on 14 June 2021, the inclusion of Cyprus in the first category of foreign investment...

Thursday, 26 May 2022 10:43

  Cyprus – TAX- amendment to the Income Tax Law and Special Contribution for Defence Law for the prevention of international tax abuse, effective as of 30.12.2022.   On 31 December 2022 the...

Subscribe to our Publications

We are dedicated to providing our clients with outstanding, highly personalized, legal representation.
Chrysanthou Mylona 10 
3030 - Limassol, Cyprus
© Soteris Pittas & Co LLC. All Rights Reserved.