A non-resident is liable to pay taxes in the Republic of Kazakhstan on income from sources in the Republic of Kazakhstan in accordance with the provisions of the Tax Code.

Under the Tax Code, income of a non-resident in the form of interest is recognized as income from sources in the Republic of Kazakhstan. The term “interest” is applied in accordance with the definition set out in Article 12 of the Tax Code.

Income from sources in the Republic of Kazakhstan received by a non-resident legal entity whose activities do not result in the creation of a permanent establishment in the Republic of Kazakhstan is subject to corporate income tax withheld at source, without deductions.

At the same time, income of a non-resident in the form of interest, with the exception of interest on loans (borrowings) and debt securities, is subject to withholding tax at a rate of 15 percent. Income of a non-resident in the form of interest on loans (borrowings) and debt securities is subject to withholding tax at a rate of 10 percent.

International treaties ratified by the Republic of Kazakhstan prevail over the provisions of the Tax Code. The procedure and conditions for the application of international treaties to which the Republic of Kazakhstan is a party are determined by the legislation of the Republic of Kazakhstan.

The application by a tax agent of the provisions of an international treaty to income of a non-resident in the form of interest received from sources in the Republic of Kazakhstan is carried out in accordance with the procedure established by Article 706 of the Tax Code.

Source : https://www.gov.kz/memleket/entities/kgd/press/news/details/1156757?lang=kk