Page 30 - CEE Tax Guide 2024
P. 30

Kyrgyzstan                                                                                                              VAT options in         Applicable / limits         Personal income tax / Social security system
                                                                                                                                   Kyrgyzstan
                                                                                                                                                                                      The following are recognized as tax residents: citizens
                                                                                                                                                                                      of the Kyrgyz Republic and any individual remaining in the
                                                                                                                                   Distance selling                No
                                                                                                                                                                                      Kyrgyz Republic for at least 183 calendar days in any
                                                                                                                                   Call-off stock                  No                 consecutive 12-month period ending in the current tax
                               Mazars LLC                                                                                          VAT group registration          No                 period (calendar year).
                               118 Moskovskaya st., 5  floor,                                                                                                                         All types of income are taxed at a rate of 10% regardless
                                                th
                               Business center Olymp                                                                               Cash accounting – yearly   Available without limits.  of the tax residency status of the individual and the type
                                                                                                                                   amount in EUR (approx.)
                               Bishkek, Kyrgyzstan                                                                                                                                    of incomes received.
                               Phone: +996 312 882 155                                                                             Import VAT deferment            No
                               E-mail: infoca@mazars.kz                                                                            Local reverse charge            ü                  The following social contributions are withheld from

                                                                                                                                   Option for taxation                                employee income: 8% to the Pension Fund, 2% to the State
                                                                                                                                                                                      Pension Fund. The following social contributions are paid
                                                                                                                                       letting of real estate      No                 by an employer on employee income: 15% to the Pension
                                                                                                                                                                                      Fund, 2% to the Compulsory Health Insurance Fund, and
                                                                                                                                   supply of used real estate      No
           Corporate taxes and other direct taxes               Transfer pricing in Kyrgyzstan                                     VAT registration                                   0.25% to the Employee Health Improvement Fund.

           Taxable income is calculated as annual income minus   Arm's length principle   ü    Since 2009                          threshold                       No
           expenses. Only properly documented expenses may
           be deducted, provided that expenses are related to the                           Documentation is not
           taxable income. Dividends and capital gains are excluded   Documentation liability  No  required, but benchmarking
                                                                                           must be provided at the tax
           from taxable income. The percentage of depreciation                               authority’s request.
           norms for fixed assets is set out in the Tax Code and
           is substantively similar to IFRS principles. Losses can   APA            No             –
           be carries forward within the following 5 calendar years   Country-by-Country
           inclusively; the rule on carrying forward losses does not   liability    No             –
           apply to losses generated during periods when a company
           enjoyed tax benefits. There are no thin capitalization rules.    Master file-local file
                                                                (OECD BEPS 13)
           WHT is applied to incomes paid to non-residents that are   applicable     –             –
           not registered for tax purposes in Kyrgyzstan. Taxable   Penalty
           incomes are listed in the Tax Code. Kyrgyzstan has signed
           32 treaties on the avoidance of double taxation. Though   lack of documentation   No    –                                                                                                               Average wage
           the treaty rates prevail over the Tax Code, it is important             penalty.                                        Wage related taxes in Kyrgyzstan                    Minimum wage               in private sector
           to have a duly issued tax residency certificate for the non-  tax shortage      From 10% to 100% of the
           resident to apply the treaty. The multilateral instrument                ü          tax shortage.                       Exchange rate KGS/EUR                                                  97  in EUR  in KGS  in EUR  in KGS
           (MLI) is not in force.                                                                                                                                                          191          18,500       464              45,000
                                                                                            Interdependent entities
           VAT and other indirect taxes                                                    are entities whose relations            Total wage cost                                        224      117.25%           544      117.25%
                                                                                           may affect the conditions
           The VAT concept is quite similar to the concept applied                         or economic results of their                     Employer's social security and other contributions   33      17.25%       80      17.25%
           in developed countries worldwide. Turnover subject to VAT                     activities or those of the entities       Gross salary                                            191      100.00%          464      100.00%
           is in general the total value of sales (Output VAT). VAT paid                    they represent, namely:                                               Personal income tax      19      10.00%             46      10.00%
                                                                                            1) An entity has a direct
           to suppliers (input VAT) is deducted from Output VAT.                            or indirect participation                                         Employees' contributions      17      9.00%             42       9.00%
           Input VAT cannot be offset if the goods, works, or services                     in another entity and the
                                                                                            aggregate share of such
           purchased are not related to the taxable turnover,                            participation is more than 20%;           Net salary                                             154      81.00%            376      81.00%
           the VAT-invoice is not issued by a supplier or is issued                       2) Two entities in which a third
           in violation of legal requirements, the supplier is declared                    entity holds participation
                                                                                          and its direct and/or indirect
           by court as inactive entity, etc. The VAT rate for the export   Related parties  interest in each entity is more
           of goods is 0% and there is a procedure for refund of the                       than 20%, or is controlled
           related input VAT. A special VAT procedure applies to the                          by such an entity;
                                                                                             3) When one natural
           export/import of goods to/from the countries belonging                           person is subordinate
           to the Eurasian Economic Union such as Russia, Belarus,                         to another natural person
           Kazakhstan, and Armenia.                                                         in an official capacity;
                                                                                           4) Entities between which
           Sales tax applies to revenue besides VAT. The rate varies                      there are relations regulated
           from 0% to 5% depending on the type of activity and                            by the labor legislation of the
                                                                                              Kyrgyz Republic;
           whether the revenue was received in cash or not.                                   5) Close relatives;
                                                                                             6) The founder of the
           Excise tax is paid by importers and sellers of:                                management and the trustee.
                                                                                                                                                 Ludmila Dyakonova
           1) Alcoholic products
                                                                Safe harbors        ü            20%                                             Partner
           2) Tobacco products                                                                                                                   Phone: +7 727 355 40 00
                                                                Level of attention paid by Tax
           3) Oil products.                                     Authority                        8/10                                            E-mail: ludmila.dyakonova@mazars.kz

           30    Mazars                                                      Central and Eastern European tax guide 2024          Central and Eastern European tax guide 2024                                             Mazars   31
   25   26   27   28   29   30   31   32   33   34   35