Controversial Issues of Taxation of Non-resident Branches in Kazakhstan

Controversial Issues of Taxation of Non-resident Branches in Kazakhstan
Event Date: November 11, 2020
Event Time: 16:00 - 17:00
Venue: Online Webinar
Location: Nur-Sultan, Kazakhstan

Dear Members and Partners,

We are delighted to invite you to the webinar on topic ‘Controversial issues of taxation of non-resident branches in Kazakhstan’ organized in cooperation with PwC and the British Embassy in Kazakhstan.

The following issues will be discussed during the webinar:

  • Recognition of inactive branches of non-residents as permanent establishment in Kazakhstan;
  • Recognition of a non-resident's income as the income of its Kazakhstan branch, if the latter has no capacity to provide it;
  • Branches of non-residents in Kazakhstan that provide other work and services than the head office;
  • Application of a reduced withholding tax rate when paying passive income to a non-resident who has a branch in Kazakhstan;
  • Imputation of a tax obligation to a tax agent to withhold a tax from non-resident’s income received from another tax agent previously;
  • Current issues from the tax authorities to non-resident’s branches in Kazakhstan;
  • Application of transfer pricing control for transactions between branches and the non-resident head office.


Richard Bregonje – Partner, Tax and Legal Services

Dana Tokmurzina – Partner, Dispute Resolution & Regulatory

Nursultan Nurbayev – Senior Manager, Transfer Pricing and Dispute Resolution Services

Aliya Ibrayeva – Senior Manager, International Taxation Services

Olzhas Kassenov – Senior Consultant, Dispute Resolution & Regulatory

Date: November 11, 2020
4 p.m. – 5 p.m. (Nur-Sultan time)
Language of the webinar: English

With thanks,
British Chamber of Commerce in Kazakhstan


Founding Members

Air Astana JSC KPMG Tax and Advisory LLC Rio Tinto Mining and Exploration Limited