Page 31 - CEE Tax Guide 2024
P. 31

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

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