Netherlands Has Published A Tax Convention With Kazakhstan Synthesized With MLI

Recently Netherlands published a Convention for the avoidance of double taxation with Kazakhstan ("the Convention"), that incorporates provisions of the Multilateral Convention ("MLI") chosen by the Netherlands and Kazakhstan. These provisions directly impact or replace the Convention. It should be noted that such an official document is easy to use and minimizes the probability of mistakes in applying the Convention.

Let's look at these changes and give some examples:

• Article 4.1 of MLI changes Article 4.3 of the Convention. This amendment applies to legal entities with dual residence. In case of conflict related to a dual residence, such residence will not be determined by the place of management, but by mutual agreement of competent authorities. If the conflict is not solved, an entity will not receive any benefits.