Kazakhstan has approved a Protocol updating its 2001 tax treaty with Norway, introducing a 5% withholding tax rate on qualifying dividends and strengthening Permanent Establishment (PE), information exchange, and anti-abuse rules. The amendments will take effect after both countries complete their domestic ratification procedures.
Kazakhstan’s government approved the signing of an amending protocol to its 2001 tax treaty with Norway to align the agreement with modern international tax standards.
Approved on 29 July 2026, the protocol updates provisions on Permanent Establishment (PE), expands exchange of information, and introduces a 5% withholding tax rate on dividends where the beneficial owner is a company that directly holds at least 10% of the capital for a continuous period of 365 days.
The amendments also introduce anti-abuse measures, including the Limitation of Benefits (LOB) provision and the Principal Purpose Test (PPT), to prevent treaty shopping and inappropriate access to treaty benefits.
The Protocol will enter into force after both countries complete their domestic ratification procedures, with withholding tax changes applying from the second month after entry into force and other provisions taking effect from 1 January of the following year.
