We are pleased to announce that an article by our colleague, Saule Kassymkhanova, entitled “Tax Treaty Benefits under Scrutiny: How the Principal Purpose Test Changes the Rules for Know-How and Royalties”, has been published in the proceedings of the MNU Annual Legal Conference – 2026.
The article examines how the Principal Purpose Test affects access to double tax treaty benefits in cross-border transactions involving know-how, royalties and related services. It also proposes a practical two-stage approach to documenting the commercial rationale and substance of such transactions in order to mitigate the risks of payment reclassification, denial of treaty benefits and double taxation.
The conference proceedings are available at the link below. See page 255 for Saule Kassymkhanova’s article.
https://nara.mnu.kz/items/84d8017c-2703-42e3-a7d0-bf2ee7a77e44
