Permanent establishment risk in Kazakhstan

Risks of permanent establishments in accordance with international concepts and the agreement between Russia and Kazakhstan on avoidance of double taxation.

Under the general rules, each company pays income tax in its home country. If a foreign company carries on activities in another state (e.g., Kazakhstan) that give rise to a permanent establishment, it must pay income tax on those activities in that other state.

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Our services

We offer services to assess the risks of recognizing permanent establishments in accordance with international OECD concepts and/or the agreement between Russia and Kazakhstan on avoidance of double taxation:

  • Analysis of business processes for the risks of recognizing a permanent establishment for tax purposes;
  • Recommendations on changing the scheme of work in Kazakhstan to reduce the risk of permanent establishment;
  • Calculation of the safe amount of profit of the permanent establishment;
  • Assistance in correspondence with tax authorities.

Leading positions

Konsu is one of the leading consulting companies in Russia. We have been included in the following ratings of the rating agency Expert RA:

  • Top-10 in accounting outsourcing
  • Top-10 in payroll outsourcing
  • Top-15 in financial consulting
  • Top-15 in legal consulting
Ratings and associations