Alert: Pillar 2 In Kazakhstan

On 04 July 2024 a draft of the Ruling of the Government of the Republic of Kazakhstan 'On signing of the Multilateral convention to facilitate the implementation of the pillar two subject to tax rule'¹ ('Pillar 2') was published.

Pillar 2 is one of the instruments of the Organisation for Economic Cooperation and Development (OECD) aimed at counteracting base erosion and profit shifting (BEPS). Pillar 2 was drafted in order to ensure that multinational corporations pay certain amount of tax in intra-group transactions in those jurisdictions where they operate.

Pillar 2 is applicable to the following types of income:

• interest;
• royalty;
• fee for use or right to use product or service distribution rights (except for fees which represent 8.5% or less mark-up on costs on granting of such rights);