On 24 June 2020, Kazakhstan notified the OECD that it has completed its internal procedures for the entry into effect of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (Multilateral Instrument or MLI). This means that MLI will apply to the Netherlands – Kazakhstan DTT as per 1 January 2021 with respect to withholding taxes and with respect to other taxes (on tax book years starting) as per 1 April 2021.
The MLI is a legal mechanism to ensure that the anti-BEPS (i.e. Base Erosion and Profit Shifting) actions are deemed included in existing double tax treaties (DTT) without the actual amendment thereof, provided that both parties of the DTT have enacted MLI and therefore consider a particular DTT as ‘Covered Tax Agreement’ and, with respect to the optional provisions, only if and insofar the two countries have chosen the same options on how the articles of the MLI should apply to all of their existing treaties.
In the document below you will find a summary on the relevant articles of the MLI which will change the provisions of The Netherlands – Kazakhstan DTT.
On November 6, 2020 Luxembourg and Russia signed a protocol amending the existing double tax treaty, which increases the maximum withholding
The Russian Ministry of Finance recently sent a letter to the Dutch Ministry of Finance in which Russia expressed its preference to amend the tax treaty between the Netherland
On 30 April 2020, the Russian Federation notified the Secretary-General