Interest arising in Kazakhstan and paid to a resident of the
United Kingdom who is the beneficial owner of the interest is
taxable in Kazakhstan at a rate not exceeding 10 per cent (Article
11(2)),except where the interest is effectively connected with a
permanent establishment or fixed base which the UK resident
recipient has in Kazakhstan. In the latter circumstances the
provisions of the Business Profits Article (Article 7) or the
Independent Personal Services Article (Article 14) will apply.
Where Kazakhstan source interest is paid to a United Kingdom
resident who is the beneficial owner of the interest, in respect of
a loan made, guaranteed or insured by the United Kingdom Export
Credits Guarantee Department, it is exempted from Kazakhstan tax
(Article 11(11)).
With effect from 1 January 1999, interest paid by the
Government of Kazakhstan or by a local authority of Kazakhstan is
exempted from Kazakhstan tax (Article 11(10)).
