Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

intl-updates-small.jpg
lopatina.JPG

Irina Lopatina

On June 22 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on October 13 2016. Currently, the ratification from the Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the presidents.

The 2016-signed treaty covers taxes on income and profit taxes. In the case of Georgia, these would be the profit tax and income tax, while in Kyrgyzstan the income tax on individuals and tax on income and profits of legal persons. The agreement will also be applicable to similar taxes that may be imposed at a later stage, on the condition that the signatory parties notify each other about the tax changes introduced.

Permanent establishments (PEs) are deemed to arise when a building, construction site or an installation project or related supervisory activity lasts for more than six months. Additionally, a PE also includes a place of management, a branch, an office, a factory, a workshop or a mine or oil/gas well.

In terms of withholding tax rates, dividends are to be taxed at 5% of the gross amount of the dividends if the beneficial owner holds at least 25% of the capital of the company paying the dividends and 10% of the gross amount of the dividends in all other cases. The withholding tax rate for interest has been set at 5%, while for royalties at 10%.

Once the double tax agreement enters into force its provisions shall have effect in respect of taxes withheld at source on or after the first day of January of the year following the one during which the agreement enters into force.

Irina Lopatina (irina.lopatina@eurofast.eu), Tbilisi

Eurofast Global

Tel: +995 322180310

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
The UK accountancy firm’s transfer pricing lead tells ITR about his expat lifestyle, taking risks, and what makes tax cool
Dolphin Drilling intends to discuss the final liability amount and manner of settlement with HM Revenue and Customs
Winning the case against the 20% VAT imposition was always going to be an uphill challenge for the claimants, UK tax advisers argue
A ‘paradigm shift’ in Chile’s tax enforcement requires compliance architecture built on proactive governance, strategic documentation and active monitoring of judicial developments
Gift this article