Article 706. Procedure for applying an international agreement on income of a non-resident in the form of dividends, remuneration and (or) royalties received from sources in the Republic of Kazakhstan tax code of the Republic of Kazakhstan
1. when paying income in the form of dividends, remuneration and (or) royalties to a non-resident or when deducting unpaid income in the form of remuneration and (or) royalties to a non-resident, unless otherwise established by an international treaty, the tax agent shall comply with the following conditions::
1) conclusion and ratification of an international treaty with the resident state of a non-resident;
2) independently apply the provisions of an international treaty if a document confirming the residency of a non-resident is submitted within the time limits established by paragraph 3 of Article 705 of this code.
The document confirming the residency of a non-resident must meet the requirements established by Article 702 of this code;
3) the income paid is not related to the activities of the permanent institution of the non-resident in the Republic of Kazakhstan;
4) the non-resident has the right to independently apply the provisions of an international treaty, unless he is the recipient of the final income.
For the purposes of this section, an intermediary, including an agent, a person who is not a nominal holder (the actual owner), who has the right to own, use, dispose of income and in relation to such income, should be understood as the recipient of final income.
2. when paying income in the form of remuneration through an intermediary to the recipient of the final income, the tax agent simultaneously fulfills the following conditions::
1) in the contract (contract) on the basis of which remuneration is paid::
the name of the intermediary, the amounts of payments and remuneration paid to the intermediary, and the amounts of remuneration for each final remuneration recipient through the intermediary;
data of the intermediary and such a person (surname, first name and patronymic of an individual or names of a legal entity);
tax registration number in the country of incorporation or its analogue (if any);
if the state registration number (or its analogue) in the country of incorporation is indicated;
2) Apply an exemption from income tax or its reduced rate provided for by an international agreement concluded with the state in which such final recipient is a resident, if a document confirming the residency of the final recipient is submitted within the time limits established by paragraph 3 of Article 705 of this code.
The document confirming the residency of the final recipient must meet the requirements established by Article 702 of this code.
3.the tax agent is obliged to submit to the tax authority at his place of residence a copy of the document confirming the residence of the final recipient no later than five calendar days from the date established for submission of tax reports for the fourth quarter.
4.in case of non-application by the tax agent of the provisions of an international treaty, the tax agent is obliged to withhold and transfer income tax from the source of payment in accordance with the procedure and terms provided for in articles 683 and 684 of this code.
5.if a tax agent transfers to the budget the income tax withheld from the source of payment by a non-resident-the recipient of final income, he has the right to return the income tax withheld from the source of payment to such a non-resident in accordance with the provisions of an international treaty.
Refund of excess withheld income tax to a non-resident is made by a tax agent.
At the same time, the non-resident is the recipient of the final income to the tax agent:
1) the following:
the amount of remuneration of such a non-resident, indicating the data of such a person (surname, first name and patronymic of an individual or names of a legal entity) ;
tax registration number in the country of incorporation (or its analogue) when it exists;
a notarized copy of the contract (contract) concluded with the intermediary, indicating the state registration number (or its analogue) in the country of incorporation;
2) provide such a non-resident with a document confirming the non-resident's residence for the period for which income in the form of remuneration is recorded.
The documents specified in part two of this paragraph are submitted by the non-resident from the date of the last transfer of income tax withheld from the source of payment to the budget until the limitation period for filing a claim expires, unless other deadlines are established by an international agreement.
6.in case of Return of income tax withheld to a non-resident in accordance with paragraph 5 of this article, the tax agent has the right to submit to the tax authority at his / her place of residence a reduced tax rate for the tax period in which the withholding and transfer of income tax from income in the form of remuneration of the recipient of the final
In this case, the offset to the tax agent of the overpaid amount of income tax withheld at the source of payment is made in accordance with the procedure established by this code.
Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII kr
President
Republic of Kazakhstan
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To recognize as invalid the Code of the Republic of Kazakhstan (tax code) of December 25, 2017 "on taxes and other mandatory payments to the budget" from January 1, 2026 in connection with the entry into force of the tax code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII.
Article 706. Terms of payment of certain types of taxes and payments to the budget Code of the Republic of Kazakhstan on taxes and other mandatory payments to the budget (tax code)
1. payment of a single land tax, payment for the use of water resources of surface sources shall be made in the following order::
1) payment of accrued amounts from January 1 to October 1 of the tax period – no later than November 10 of the current tax period;
2) payment of accrued amounts from October 1 to December 31 of the tax period – no later than April 10 of the tax period following the reporting tax period.
2.payment of a single land tax to the budget is made at the place where the land plot is located.
On taxes and other mandatory payments to the budget (tax code) on customs regulation On Subsoil and subsoil use administrative procedural and procedural on Public Health and the health system Ecology social code Civil Criminal Procedure commentary (commentary) on the criminal Criminal Code normative resolution of the Supreme Court, Republic of Kazakhstan