Rules for Thin Capitalization as a Deoffshorization Tool in the Republic of Kazakhstan

The article explores some relevant issues of increasing the efficiency of fiscal policy in the Republic of Kazakhstan in the context of integration into the global community, implementation of international agreements on avoiding double taxation by Kazakhstan, and creation of favorable conditions for the development of foreign investment in the Kazakhstan economy. The problems of applying thin capitalization in terms of its impact on the investment climate are explored on the basis of the theoretical generalization of modern Kazakhstan and foreign practice of tax harbor control over some financial flows and scientific analysis of the legal regulation of transnational capital flows. Some economic and legal principles of the current practice of taxation of nonresidents in the Republic of Kazakhstan are systematized in order to determine the areas of their reform and improve the deoffshorization tools for financial flows between economic agents. The foreign experience of control over the tax base erosion in terms of remuneration for the liabilities of companies and dividends paid to foreign individuals or legal entities in the distribution of company profits is explored. The measures that allow to achieve the optimal ratio of the fiscal function and the function of encouraging the inflow of foreign capital are recommended.