Page 30 - Mazars Central and Eastern European tax guide 2023
P. 30

Kyrgyzstan                                                                                                              VAT options in         Applicable / limits         The following social contributions are withheld from
                                                                                                                                                                                      employee income: 8% to the Pension Fund, 2% to the State
                                                                                                                                   Kyrgyzstan
                                                                                                                                                                                      Pension Fund.  The following social contributions are paid
                                                                                                                                   Distance selling                No                 by an employer on employee income: 15% to the Pension
                                                                                                                                                                                      Fund, 2% to the Compulsory Health Insurance Fund, 0.25%
                                                                                                                                   Call-off stock                  No
                               Mazars LLC                                                                                          VAT group registration          No                 to the Employee Health Improvement Fund.
                               118 Moskovskaya st., 2  floor,
                                                nd
                               Business center Olymp                                                                               Cash accounting – yearly
                                                                                                                                   amount in EUR (approx.)
                               Bishkek, Kyrgyzstan                                                                                                         Available without limits.
                               Phone: +996 312 882 155                                                                             Import VAT deferment            No
                               E-mail: infoca@mazars.kz                                                                            Local reverse charge            ü

                                                                                                                                   Option for taxation
                                                                                                                                       letting of real estate      No
                                                                                                                                   supply of used real estate      No
           Corporate taxes and other direct taxes               Transfer pricing in Kyrgyzstan                                     VAT registration      30 mKGS (approx. 324 kEUR)

           Taxable income is calculated as annual income minus   Arm's length principle   ü    Since 2009                          threshold
           expenses. It is possible to deduct only properly                                  Documentation is
           documented expenses provided that expenses are                                     not required, but                   Personal income tax / Social security system
                                                                                              benchmarking
           connected with the taxable income. Dividends and capital                           must be provided                    The following are recognised as tax residents: citizens
           gains are excluded from taxable income. The percentage   Documentation liability  No  at the tax                       of the Kyrgyz Republic, any individual remaining in the
           of depreciation norms for fixed assets is set in the Tax Code                        authorities                       Kyrgyz Republic for at least 183 calendar days in any
           and is similar to IFRS principles in substance. Loss carry                           request.                          consecutive 12-month period ending in the current tax
           forward is available within the following 5 calendar years   APA         No             –                              period (calendar year).
           inclusively; the rule on carry forward of the losses does not   Country-by-Country      –
           apply to losses generated during periods when a company   liability      No                                            All types of income are taxed at a rate of 10% regardless
           enjoyed tax benefits. There are no thin capitalization rules.    Master file-local file                                of the tax residency status of the individual and the type
                                                                (OECD BEPS 13)                                                    of incomes received.
           WHT is applied to incomes paid to non-residents that are   applicable
           not registered for tax purposes in Kyrgyzstan. The taxable   Penalty
           incomes are listed in the Tax Code. Kyrgyzstan has signed
           32 Treaties on the Avoidance of Double Taxation. The treaty   lack of documentation   No  –                             Wage related taxes in Kyrgyzstan                    Minimum wage                Average wage
           rates prevail over the Tax Code, however it is important                                                                                                                                               in private sector
           to have a duly issued tax residency certificate for the non-  tax shortage  ü   From 10% to 100% of the                 Exchange rate KGS/EUR                                                  92.80  in EUR  in KGS  in EUR  in KGS
           resident to apply the treaty. The Multilateral instrument                           tax shortage.
           (MLI) is not in force.                                                         Interdependent entities are                                                                     129           12,000         377           35,000
                                                                                            entities whose relations               Total wage cost                                         152      117.25%           442      117.25%
           VAT and other indirect taxes                                                    between them may affect
                                                                                           the conditions or economic                       Employer's social security and other contributions    22      17.25%       65      17.25%
           The VAT concept is quite similar to the concept applied                         results of their activities or          Gross salary                                            129      100.00%           377      100.00%
           in the developed countries worldwide. Turnover subject                          those of the entities they
                                                                                             represent, namely:
           to VAT is in general the total value of sales (Output VAT).                      1) An entity participates                                             Personal income tax       13      100.00%            38      100.00%
           VAT paid to suppliers (input VAT) is deducted from Output                       directly or indirectly in an                                       Employees' contributions      13      10.00%             38      10.00%
                                                                                           entity and the aggregate
           VAT. Input VAT cannot be offset if the goods, works,                            share of such participation             Net salary                                              103      80.00%            302      80.00%
           services purchased are not related to the taxable turnover,                     is more than 20 percent;
           the VAT-invoice is not issued by a supplier or is issued                        2) Two entities in which a
                                                                                            third entity participates
           with the violation of the legal requirements, the supplier                     whose direct and/or indirect
           is declared by court as inactive entity, etc. The VAT rate for   Related parties  interest in each entity is
           export of goods is 0% and there is a procedure for refund                      more than 20 per cent, or is
           of the related input VAT. A special VAT procedure applies                      controlled by such an entity
                                                                                          3) When one natural person
           to the export/import of goods to/from the countries                             is subordinate to another
           belonging to the Eurasian Economic Unit such as Russia,                         natural person in an official
                                                                                                capacity
           Belarus, Kazakhstan and Armenia.                                                4) Entities between which
           Sales Tax applies to revenue besides VAT. The rate varies                      there are relations regulated
                                                                                           by the labour legislation of
           from 0% to 5% depending on the type of activity and                               the Kyrgyz Republic
           method of receipt of the revenue in cash or in not.                               5) Close relatives;
                                                                                             6) The founder of the
           Excise Tax is paid by importers or sellers of:                                   management and the
                                                                                                 trustee.                                        Ludmila Dyakonova
           1) Alcoholic products                                                                                                                 Partner
           2) Tobacco products                                  Safe harbours       ü            20%                                             Phone: +7 778 873 7159
           3) Oil products.                                     Level of attention paid by Tax                                                   E-mail: ludmila.dyakonova@mazars.kz
                                                                Authority                        8/10

           30    Mazars                                                      Central and Eastern European tax guide 2023          Central and Eastern European tax guide 2023                                             Mazars   31
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