Part 1: Kazakhstan in Holding, Financial Structures, and Personal Asset StructuringOverview: Geographical location, non-"unfriendly" status, taxes, historical use in international structures
International Structures with Assets in Kazakhstan – Key Tax Aspects:- Taxation of income paid from Kazakhstan – dividends, interest and royalties. Rates, benefits, and application of tax treaties
- Taxation upon the sale of Kazakhstani companies: three-year exemption and subsoil users
- Judicial practice on cross-border payments: disputes over withholding tax, the beneficial owner concept, and MLI
- Application of reduced tax rates – practical examples and expectations for the tax changes
Using Kazakhstan for Holding Foreign Assets:- Tax advantages and disadvantages
- Controlled foreign company rules
- Is there an "exit tax" in Kazakhstan?
- Practical case: A fund in the AIFC for structuring investments
- AIFC as a platform for tax planning of investments: key tax benefits and advantages of a financial centre
Kazakhstan in Financial Structures:- Taxation of interest income, accounting for interest expenses
- Thin capitalization rules
Kazakhstan for Structuring and Holding Personal Assets:- General rules, advantages and disadvantages of the tax system
- Investment residency in the AIFC
- Restructuring assets with companies in Kazakhstan: What to pay attention to and how to avoid tax losses
Practical ExamplesQ&A