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);
