Page 31 - Mazars Central and Eastern European tax guide 2023
P. 31

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

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