The Netherlands’ Ministry of Finance has released the synthesised text of the tax treaty with Kazakhstan, clarifying the impact of the Multilateral Convention on Implementing Tax Treaty-related Measures to Prevent Base Erosion and Profit Shifting (MLI).
This synthesised text is based on the reservations and notifications provided by each country to the Depositary. It explains the avoidance of double taxation and the prevention of fiscal evasion concerning taxes on income and capital, and the Protocol signed on 24 April 1996 as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) signed by the Netherlands on 7 June 2017 and on 25 June 2018 by Kazakhstan.
The MLI applies to the 1996 Netherlands-Kazakhstan tax treaty:
Entry into effect of the MLI provisions:
In accordance with paragraph 1 of Article 35 of the MLI, the provisions of the MLI (other than Article 16 (Mutual Agreement Procedure) and Part VI (Arbitration) have effect with respect to this Convention:
- With respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
- With respect to all other taxes levied by each State, for taxes levied concerning taxable periods beginning on or after 1 April 2021.
