For the purposes of the Elimination of double taxation Article,
profits, income or capital gains owned by a resident of the United
Kingdom which may be taxed in Kazakhstan under the provisions of
the agreement are deemed to be profits, income or capital gains
from sources in Kazakhstan (Article 22(3)).
Interest is usually deemed to arise in the State in which
the payer is resident, including where the payer is the State
itself or a political subdivision or local authority thereof. The
exception is where the person paying the interest, has, in one of
the countries, a permanent establishment or fixed base in
connection with which the indebtedness on which the interest is
paid was incurred, and such interest is borne by that permanent
establishment or fixed base. In such a case the interest is deemed
to arise in the State in which the permanent establishment or fixed
base is situated (Article 11(5)).
