The convention between France and Kazakhstan was signed in Paris on February 3, 1998. It concerns taxes on income and capital and has been amended by the Multilateral Investment Convention (MLI) since 2021. It caps withholding tax at 5 or 15 13 T on dividends, and at 10 13 T on interest and royalties. This page reads the consolidated text.
A text from 1998, including wealth tax
The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it as "IR – IF" and makes no mention of inheritance or gifts. It was approved by Law No. 2000-335 of April 14, 2000, and published by Decree No. 2000-991 of October 4, 2000. Article 2, paragraph 3, specifically mentions, for France, income tax, corporation tax, payroll tax, and wealth tax, and for Kazakhstan, income tax and tax on the assets of legal entities and individuals; the IFI (French wealth tax) is not listed. Article 2, paragraph 4, refers to similar taxes established after the signing of the agreement. According to the BOI-ANNX-000511 list, the MLI takes effect on January 1, 2021 for taxes withheld at source and on April 1, 2021 for other taxes.
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 10 § 2 | 5 % of the gross amount if the beneficiary is a company that holds at least 10 % of the capital of the paying company, throughout a period of 365 days including the day the dividends are paid; 15 % in all other cases |
| Interests | 11 § 2 | The tax cannot exceed 10 % of the gross amount |
| Royalties | 12 § 2 | The tax cannot exceed 10 % of the gross amount; for remuneration for the use of industrial, commercial or scientific equipment, option for taxation on the net amount (§ 4) |
| Capital gains on shares | 13 § 1 b) | Taxable in the other State if, at any time during the 365 days preceding the transfer, the shares derive directly or indirectly more than 50% of their value from real estate situated in that State |
| Other capital gains | 13 § 4 | Taxable only in the state where the transferor is resident |
| Salaries, exception | 15 § 2 a) | A stay not exceeding a total of 183 days during any period of twelve consecutive months beginning or ending during the tax year in question |
| Pensions and annuities | 18 § 1 | Taxable only in the state of residence |
| Real estate fortune | 22 § 1 a) | Taxable in the state where the property is located |
| Double taxation (France) | 23 § 1 a) | Tax credit deductible from French tax, equal depending on income to the corresponding French tax or the tax paid in Kazakhstan |
Who is a resident?
Article 4, paragraph 2, first considers the State where the person has a permanent home. If the center of their vital interests cannot be determined, it then considers other criteria, including nationality (paragraph c). Finally, the competent authorities decide by mutual agreement (paragraph d).
Capital gains: the real estate hidden within stocks
Article 13, paragraph 1(b), concerns shares and similar rights or interests. Gains from such shares are taxable in the State where the real estate is located if, at any time during the 365 days preceding the transfer, these shares derive, directly or indirectly, more than 50% of their value from real estate situated in that State. Real estate used by the company for its own industrial, commercial, or agricultural operations, or for the exercise of a professional activity, is excluded. Income from real estate is governed by Article 6, paragraph 1.
Fortune: Real Estate First
For real estate assets referred to in Article 6, Article 22 specifies the State in which they are located. Other assets are not detailed here; their application to the French wealth tax (IFI) has not been established.
What this page does not cover
The other conditions for holding dividends, the entitlement clause under the MLI, Articles 14, 16, 17, and 19, the exchange of information, and the details of Article 23 are not included. Kazakh law is not addressed; its validity should be verified with a local professional.
Frequently asked questions
What is the withholding tax rate on royalties between France and Kazakhstan?
10 % of the gross amount (Article 12 § 2). For remuneration for the use of industrial, commercial or scientific equipment, the beneficiary may opt, for each tax year, for taxation on the net amount as business profits (Article 12 § 4); the rate of 10 % does not then apply.
Does the France-Kazakhstan convention cover inheritances?
No, according to the administrative list of April 29, 2026, which classifies it as "IR - IF": wealth tax is targeted, no inheritance or gift is mentioned.
Is the 183-day threshold calculated on a calendar year basis?
Article 15 § 2 a) includes any period of twelve consecutive months, which must begin or end during the fiscal year in question.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, assists executives and families whose assets or business activities have ties to France and Kazakhstan. To discuss your situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- Tax treaties: countries linked to France
- Dividends paid to a non-resident: withholding tax of 12.8% %
- Capital gains on non-resident securities: when France taxes
- Wealth tax for non-residents: taxable assets and the €1.3 million threshold
- Double taxation: tax credit and effective tax rate
- Leaving France: exit tax, tax residence, procedures
Official sources
- BOFiP doctrine, France-Kazakhstan convention (BOI-INT-CVB-KAZ): https://bofip.impots.gouv.fr/bofip/461-PGP.html
- Consolidated text of the convention as amended by the MLI: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/kazakhstan/kazakhstan_modifiee_cml.pdf
- List of tax treaties (BOI-ANNX-000306): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
- List of agreements modified by the MLI (BOI-ANNX-000511): https://bofip.impots.gouv.fr/bofip/14854-PGP.html/identifiant=BOI-ANNX-000511-20260429
