Emerging Markets Rates and Currencies Handbook

159 Citi | Emerging Markets Currencies Handbook 2021 Kazakhstan Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 15% WHT • Under certain tax treaties can be reduced to 10% 15% WHT N/A 15% WHT on dividends • Under certain tax treaties can be reduced Non-resident can be WHT exempt on dividends if certain conditions are met: dividends not paid to “black-listed” jurisdictions, holding period above 3 years, etc. Deductibility of interests Thin capitalisation rule: Deductible interest limited to “acceptable” proportion of Debt-to-Equity of 7x for financial institutions (4x for all other entities) List of jurisdictions with privileged taxation ‘black list Transfer pricing rules apply (i.e. arms length rule) N/A N/A Deductibility of FX losses FX losses in excess of FX gains are deductible Only deliverable forward and NDF available locally • All other derivatives booked out of Citi London/CGML FX losses in excess of FX gains are deductible FX losses on DF are deducted from current year P&L FX losses from NDF can be deducted only from potential gains of future NDF deals within 10 year tenor (applicable only to local corporates) N/A Other taxes, duties N/A N/A N/A N/A N/A Comments N/A N/A N/A N/A N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources. Subsidiary Funding — Tax Consideration Tax Summary — Kazakhstan