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 work 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 distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

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

Creator

• Baigenzhenova, Z

Subject

• allocation of expenses
• deductions
• head office
• PE
• tax code
• tax treaty
• non-resident

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

Geographic coverage

• Asia
• North America

Index

no index present

Language note

English

Literary form

non fiction