On approval of the Protocol on amendments to the convention on the elimination of double taxation of income and property increases and the Prevention of tax evasion, signed in London on March 21, 1994 between the Government of the Republic of Kazakhstan and the Government of the United Kingdom of Great Britain and Northern Ireland on behalf of the States

Law of the Republic of Kazakhstan dated July 9, 1998 No. 275-I

     To approve the Protocol on amendments to the convention between the Government of the Republic of Kazakhstan and the Government of the United Kingdom of Great Britain and Northern Ireland signed on behalf of the Contracting States on March 21, 1994 in London on the abolition of double taxation of income and property increases and the Prevention of tax evasion, drawn up in London on September 18, 1997.

     President Of The Republic Of Kazakhstan

  Protocol on amendments to the Convention on the abolition of double taxation of income and property value increases and the Prevention of tax evasion, signed between the Government of the Republic of Kazakhstan and the Government of the United Kingdom of Great Britain and Northern Ireland on 21 March 1994 Z960012_london behalf of the contracting states

(Bulletin of international treaties of the Republic of Kazakhstan, 1999, N 5, Article 92) (entered into force on November 2, 1998 - "Bulletin of diplomacy", Special Issue N 2, September 2000, page 75)

     The Government of the Republic of Kazakhstan and the Government of the United Kingdom of Great Britain and Northern Ireland: with the intention of concluding a protocol between the Contracting Parties on amendments to the convention (hereinafter referred to as the Convention) on the abolition of double taxation of income and property value increases and the Prevention of tax evasion, signed in London on 21 March 1994; :

  Article 1

     Paragraph 10 of Article 11 of the convention shall be removed and replaced by the paragraph below: "10. Regardless of the provisions of Paragraph 2 of this article, but without prejudice to the provisions of Paragraph 4 of this article, if: (a) the interest arising in the Contracting State and paid to a resident of another Contracting State is paid by the Government of the first said state or its local authority or any work or structural unit of that government or local authority, or (B) the Government of another Contracting State or its local authority or any work or structural unit of that government or local authority, or- if the incoming work or structural unit is their recipient and actual owner, they are exempt from tax in the first named Contracting State."

  Article 2

     Immediately after paragraph 7 of Article 25 of the convention, the following new points are added: "8. As of paragraph 10 of this article, nothing in this convention shall be deemed to impede the taxation of a Contracting State in any tax year of a company resident of the second Contracting State, in addition to the tax levied on this profit in accordance with Article 7 of this convention, in addition to the tax levied on this profit,  -       a) the amount of additional tax shall not exceed 5 per cent of the company's income, which was not included in such additional tax accounting in the previous tax years, and B) the amount of profit attributable to a permanent institution in this tax year shall be greater than £ 70,000.       9. In Paragraph 8 of this article, the term "income" refers to the profit (including any income derived from the exclusion of movable property that constitutes part of the business property in accordance with Article 7(Article 13 (3) of the convention) for said permanent establishment in any tax year in which paragraph 8 of this article is in force) for said permanent establishment, from which, in accordance with Articles 7 and 13       10. If, for any tax year in which paragraph 8 of this article is in force, the Convention on the abolition of double taxation is in force between Kazakhstan and a member state of the Organization for Economic Cooperation and development, which does not provide for the collection of additional tax described in this paragraph for a permanent institution of a company that is a resident of this OECD member state, then this paragraph will not be effective for a permanent institution of a company that is a resident of the United Kingdom."

  Article 3

     1.each Contracting State shall notify the other state through diplomatic channels of the completion of the procedures required by its laws for the entry into force of this protocol.       2.this Protocol shall enter into force from the date of receipt of the last of these notifications and shall be in force after that: A) in respect of taxes arising in Kazakhstan in taxable periods beginning on or after the first of January of the calendar year following the entry into force of this protocol.       B) in the United Kingdom: (I) in respect of income tax on income and property value gains for any taxable year commencing on or after April 6 of the calendar year following the year of entry into force of this Protocol; (II) in respect of corporation tax for any financial year commencing on or after April 1 of the calendar year following the year of entry into force of this protocol;        On September 18, 1997, two copies were made in Kazakh, English and Russian, all three texts have the same power.

        Kazakhstan for the Government of the United Kingdom of Great Britain and the Northern Republic of Ireland

President    

Republic of Kazakhstan     

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