Contribution to a chartered capital is not the only way of investment into company\u2019s business.<\/p>\n
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Alternative option would be debt instruments: direct loan, controlled bank loan or purchase of loan securities.<\/p>\n
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The main advantages of debt instruments are:<\/p>\n
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(a) investments into a chartered capital assume that return of such investments (as dividends<\/em>) could be done after payment of a corporate income tax and withholding tax, whereas debt investments when returned are not subject to corporate income tax and should be deducted from gross profit;<\/p>\n \n (b) when it comes to debt an income tax is calculated against the interest;<\/p>\n \n (c) loan interest accrued and paid is generally considered as borrower\u2019s losses;<\/p>\n \n (d) should the loan be attracted through listing of securities on the appropriate market then lenders could be offshore companies and their profit would be exempted from taxes;<\/p>\n (e) loan, together with interest could be withdrawn from the borrower at any time without waiting for financial year end and taken decision of dividends distribution;<\/p>\n (f) in some cases the loan in practicable instrument to block borrower\u2019s assets.<\/p>\n Nonetheless, the following are the cons of debt instruments:<\/p>\n (1) the Tax code of Kazakhstan is familiar with the \u2018constructive dividends\u2019 rule, thus interest paid to shareholders may be considered as dividends and taxed accordingly;<\/p>\n (2) thin capitalisation rule is also applicable by the Tax code;<\/p>\n (3) tax rate of a corporate income tax paid to an offshore entity is equal to 20%.<\/p>\n Nonetheless, the aforesaid issues could be brought under control when using a special purpose vehicle that is registered in jurisdictions that have signed a double tax treaty with Kazakhstan.<\/p>\n","protected":false},"excerpt":{"rendered":" Contribution to a chartered capital is not the only way of investment into company\u2019s business. Alternative option would be debt instruments: direct loan, controlled bank loan or purchase of loan securities. The main advantages of debt instruments are: (a) investments into a chartered capital assume that return of such investments (as dividends) could be done […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":61,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"om_disable_all_campaigns":false,"_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0},"_links":{"self":[{"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/pages\/266"}],"collection":[{"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/pari-passu.net\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=266"}],"version-history":[{"count":3,"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/pages\/266\/revisions"}],"predecessor-version":[{"id":532,"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/pages\/266\/revisions\/532"}],"up":[{"embeddable":true,"href":"https:\/\/pari-passu.net\/index.php?rest_route=\/wp\/v2\/pages\/61"}],"wp:attachment":[{"href":"https:\/\/pari-passu.net\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=266"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}