Kazakhstan has opened a public consultation on the ratification of a protocol amending its 1996 income and capital tax treaty with Iran on 5 May 2025.
The protocol, signed on 15 February 2025, marks the first update to the original treaty. It is formally titled:
“On the Ratification of the Protocol Amending the Agreement Between the Government of the Republic of Kazakhstan and the Government of the Islamic Republic of Iran on the Avoidance of Double Taxation and the Prevention of Tax Evasion with Respect to Taxes on Income and Capital of 16 January 1996 (Dey 26, 1374 of the Solar Hijri Calendar).”
The draft resolution was developed in line with Article 5(2) and Article 8(2) of Kazakhstan’s Law “On International Treaties.” Its purpose is to submit the ratification proposal to the Mazhilis, the lower house of Kazakhstan’s Parliament, for consideration.
The proposed amendments reflect OECD recommendations under the Base Erosion and Profit Shifting (BEPS) project and the Multilateral Instrument (MLI). Key changes include:
- A revised title and preamble
- New rules on permanent establishment
- A 365-day holding period requirement for reduced dividend withholding rates
- A new article on entitlement to treaty benefits
The protocol will enter into force after both countries complete the exchange of ratification instruments. Public comments on the draft may be submitted until 29 May 2025.
