The Kazakhstan tax deducted from dividends at the agreement rate
of 15 per cent (5 per cent if the recipient is a United Kingdom
company which controls directly or indirectly at least 10 per cent
of the voting power in the company paying the dividend) qualifies
for credit as a direct tax (see INTM164010(c)).
This reduced rate does not apply if the dividends are
effectively connected (see INTM153110 fifth sub-paragraph) with a
business carried on through a permanent establishment or fixed base
which the recipient has in Kazakhstan.
A United Kingdom company controlling, directly or
indirectly, at least 10 per cent of the voting power of the
Kazakhstan company paying the dividend is entitled, under Article
22(1)(b), to credit for underlying tax (see INTM164010(d)).
