On Ratification of the Protocol on Amendments to the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, as amended by the Protocol signed in Luxembourg on May 3, 2012

Home / Protocol / On Ratification of the Protocol on Amendments to the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, as amended by the Protocol signed in Luxembourg on May 3, 2012

On Ratification of the Protocol on Amendments to the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, as amended by the Protocol signed in Luxembourg on May 3, 2012

The Law of the Republic of Kazakhstan dated October 14, 2020 No. 367-VI SAM.

To ratify the Protocol on Amendments to the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, taking into account the amendments introduced by the Protocol signed in Luxembourg on May 3, 2012,Sultanah and Luxembourg on October 14, 2019.

President of the Republic of Kazakhstan

K. TOKAEV

Protocol on amendments to the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, as amended by the Protocol signed in Luxembourg on May 3, 2012

(Entered into force on November 6, 2020, Bulletin of International Treaties of the Republic of Kazakhstan 2020, No. 6, Article 27)

The Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg,

Desiring to amend the Convention between the Government of the Republic of Kazakhstan and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital, signed in Astana on June 26, 2008, taking into account the amendments made by the Protocol signed in Luxembourg on May 3, 2012 (hereinafter - the "Convention"),

have agreed on the following:

Article 1

Add paragraph 2-1 to article 10 of the Convention:

"2-1. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of one Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is:

(a) in Kazakhstan:

(i) The Government of the Republic of Kazakhstan or a central or local authority;

(ii) The National Bank of the Republic of Kazakhstan; or

(iii) any other institution wholly owned by the Government of the Republic of Kazakhstan, which may be agreed from time to time between the competent authorities of the Contracting States;

(b) in Luxembourg:

(i) The Government of Luxembourg or a local authority;

(ii) The Central Bank of Luxembourg;

(iii) "Société Nationale de Crédit et d'Investissement" (National Credit and Investment Company); or

(iv) any other institution wholly owned by the Government of Luxembourg, which may be agreed from time to time between the competent authorities of the Contracting States."

Article 2

Each of the Contracting States shall notify the other through diplomatic channels of the completion of the procedures necessary in accordance with national legislation for the entry into force of this Protocol. The Protocol, which forms an integral part of the Convention, shall enter into force on the date of receipt of the last of these notifications and shall apply in both Contracting States for taxable periods beginning on or after the first of January of the calendar year following the year of entry into force of this Protocol.

In witness whereof, the undersigned, being duly authorized thereto, have signed this Protocol.

Done in two original copies in French, Kazakh, Russian and English, all texts are equally authentic.

Nur-Sultan, October 14, 2019

Luxembourg, October 14, 2019

For the Government

Republic of Kazakhstan

The Grand Duchy of Luxembourg

IZPI's note! The text of the Protocol in French and English is attached.

President

Republic of Kazakhstan

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