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Does the Law permit non-resident beneficiaries to whom the amounts subject to the Withholding Tax have been paid to file a tax return to GAZT directly and to pay the tax based on a discretionary assessment pursuant to Article (16) of the Implementing Regulations?

The law does not permit a non-resident beneficiary to whom the amounts subject to the withholding tax have been paid to file a tax return to GAZT and to pay tax on that base, since the rate for the withholding tax is defined on the basis of a percentage of the total amount paid.​