The Resource Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
Resource Information
The item Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- In this paper, the author describes the past and current situations with regard to deductions of the amount of executive (managerial), general and administrative expenses (G&A) allocated by a nonresident to its permanent establishment (PE) located in the Republic of Kazakhstan (RK) for the purpose of corporate income tax computation due to RK budget. The author analyses the provisions of Article 6 (Business profits) of the USA-Kazakhstan tax treaty and contrasts it with domestic RK law provisions and with the practical approach adopted by the tax authorities. In particular, the author points out that RK's domestic legislation does not contain the same meaning of G&A allocation given in tax treaties, and the Tax Code of Kazakhstan's wording limits the G&A deduction amount in some instances compared with what is intended by the provision of the tax treaty. Furthermore, the author provides an overview of selected international practices in the area of Head-Office expense allocation
- Language
- eng
- Extent
- 109 p.
- Label
- Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
- Title
- Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
- Language
- eng
- Summary
- In this paper, the author describes the past and current situations with regard to deductions of the amount of executive (managerial), general and administrative expenses (G&A) allocated by a nonresident to its permanent establishment (PE) located in the Republic of Kazakhstan (RK) for the purpose of corporate income tax computation due to RK budget. The author analyses the provisions of Article 6 (Business profits) of the USA-Kazakhstan tax treaty and contrasts it with domestic RK law provisions and with the practical approach adopted by the tax authorities. In particular, the author points out that RK's domestic legislation does not contain the same meaning of G&A allocation given in tax treaties, and the Tax Code of Kazakhstan's wording limits the G&A deduction amount in some instances compared with what is intended by the provision of the tax treaty. Furthermore, the author provides an overview of selected international practices in the area of Head-Office expense allocation
- http://library.link/vocab/creatorName
- Baigenzhenova, Z
- Geographic coverage
-
- Asia
- North America
- Index
- no index present
- Language note
- English
- Literary form
- non fiction
- http://library.link/vocab/subjectName
-
- tax treaty
- non-resident
- allocation of expenses
- PE
- head office
- tax code
- deductions
- Label
- Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
- Extent
- 109 p.
- Label
- Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan
- Extent
- 109 p.
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Application-of-article-6-business-profits-of/H7mVgJqEZJ8/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Application-of-article-6-business-profits-of/H7mVgJqEZJ8/">Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Application-of-article-6-business-profits-of/H7mVgJqEZJ8/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Application-of-article-6-business-profits-of/H7mVgJqEZJ8/">Application of article 6 "business profits" of USA-Kazakhstan tax treaty with regard to executive and general administrative expenses allocation between a nonresident and a permanent establishment of such nonresident situated in Kazakhstan</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
