Download or read book Application of Article 6 "business Profits" of USA-Kazakhstan Tax Treaty with Regard to Executive and General Administrative Expenses Allocation Between a Nonresident and a Permanent Establishment of Such Nonresident Situated in Kazakhstan written by Z. Baigenzhenova and published by . This book was released on 2016 with total page 109 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this paper, the author describes the past and current situations with regard to deductions of the amount of executive (managerial), general and administrative expenses (G&A) allocated by a nonresident to its permanent establishment (PE) located in the Republic of Kazakhstan (RK) for the purpose of corporate income tax computation due to RK budget. The author analyses the provisions of Article 6 (Business profits) of the USA-Kazakhstan tax treaty and contrasts it with domestic RK law provisions and with the practical approach adopted by the tax authorities. In particular, the author points out that RK's domestic legislation does not contain the same meaning of G&A allocation given in tax treaties, and the Tax Code of Kazakhstan's wording limits the G&A deduction amount in some instances compared with what is intended by the provision of the tax treaty. Furthermore, the author provides an overview of selected international practices in the area of Head-Office expense allocation.