The relationship between international tax law and the domestic legal order: the case of Kazakhstan

Tomas Balco, Xeniya Yeroshenko


In this article the authors consider the conclusion, enforcement, application and interpretation of double tax treaties in Kazakhstan. The authors conclude that though it displays features of both monist and dualist systems, Kazakhstan is a monist state in relation to tax law, with international agreements prevailing over domestic law. The authors also consider the influence of model tax conventions on the formation of tax treaties of Kazakhstan, and put forward their opinion on the potential influence of the BEPS project on the future development of tax law in the country.


relationship between international and national law; monist system; dualist system; tax treaty override; developing country; OECD Model; UN Model; BEPS; base erosion and profit shifting

DOI: 10.6092/issn.2036-3583/5664


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