Deductions for intangible services from non-residents

At the end of April 2023 ARBAudit Company LLP participated in the online discussion of the National Chamber of Entrepreneurs "Atameken" on the issue of deductions for intangible services from non-residents.

Thus, according to the new provisions of Article 264 of the Tax Code (subparagraph 23), which came into force on January 1, 2023, the costs of acquisition of management, consulting, advisory, consulting, auditing, design, legal, accounting, advocacy, advertising, marketing, franchising, financial (except for remuneration expenses), engineering, agency services, royalties, rights to use intellectual property objects from a non-resident - related party are not deductible.

As reported by representatives of the National Chamber of Entrepreneurs "Atameken", the State Revenue Committee of the Ministry of Finance plans to amend the above norms of the Tax Code, in particular, to apply the above norms of subparagraph 23) of Article 264 of the Tax Code in respect of only non-residents registered in the state with preferential taxation.

So far, these plans are only at the discussion stage.