Part IV. Items of General Interest

U.S.–Kazakhstan Agreement on Fiscally Transparent Entities

Announcement 2015–4

The following is a copy of the Competent Authority Agreement (“the Agreement”) that was released to the public on February 2, 2015, by the Competent Authorities of the United States and Kazakhstan regarding the eligibility of entities that are treated as fiscally transparent under the laws of either Contracting State to benefits under the Convention Between the Government of the United States of America and the Government of the Republic of Kazakhstan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed on October 24, 1993 (the “Treaty”). The text of the Agreement is as follows:

COMPETENT AUTHORITY MUTUAL AGREEMENT

The competent authorities of the United States and of Kazakhstan hereby enter into the following mutual agreement (the “Agreement”) regarding the eligibility of entities that are treated as fiscally transparent under the laws of either Contracting State to benefit under the Convention between the Government of the United States of America and the Government of the Republic of Kazakhstan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, along with a Protocol, signed on October 24, 1993. The Agreement specifies the cases where fiscally transparent entities are entitled to treaty benefits and clarifies the procedure for claiming treaty benefits from one of the Contracting States. The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure).

1. Eligibility of fiscally transparent entities for treaty benefits