PwC Webinar - Controversial issues of taxation of non-resident branches in Kazakhstan

On November 11, 2020 the consulting company PwC Kazakhstan in cooperation with ADVANTAGE AUSTRIA Almaty conducted an informative webinar on the issues of taxation of non-resident branches in Kazakhstan.
© PwC Kazakhstan, ADVANTAGE AUSTRIA Almaty
© PwC Kazakhstan, ADVANTAGE AUSTRIA Almaty

This webinar was, in particular, aimed at foreign subsidiaries and non-resident branches of international companies based in Kazakhstan.

The following issues were discussed during the webinar:

  • Recognition of inactive branches of non-residents as permanent establishment in Kazakhstan
  • Recognition of a non-resident's income as the income of its Kazakhstan branch, if the latter has no capacity to provide it
  • Branches of non-residents in Kazakhstan that provide other work and services than the head office
  • Application of a reduced withholding tax rate when paying passive income to a non-resident who has a branch in Kazakhstan
  • Imputation of a tax obligation to a tax agent to withhold a tax from non-resident’s income received from another tax agent previously
  • Current issues from the tax authorities to non-resident’s branches in Kazakhstan
  • Application of transfer pricing control for transactions between branches and the non-resident head office


  • Richard Bregonje, Partner, Tax and Legal Services
  • Dana Tokmurzina, Partner, Dispute Resolution & Regulatory
  • Nursultan Nurbayev, Senior manager, Transfer pricing and dispute resolution services
  • Aliya Ibrayeva , Senior manager, International taxation services
  • Olzhas Kassenov , Senior consultant, Dispute Resolution & Regulatory

You missed the webinar? The video recording can be found here.