According to paragraph 10 of Article 184.108.40.206-1 of the Tax Code, transfer of net income of the permanent establishment of non-resident located in the countries or territories with preferential tax regime to the account of this non-resident will not be considered as income from Azerbaijani sources. The countries or territories with preferential taxation shall be the following (Article 128.1 of the Tax Code):
- countries or territories the tax rate of which is 75% or less of the rate specified in the Tax Code of the Republic of Azerbaijan and (or);
- countries or territories that do not exchange information with the Republic of Azerbaijan under relevant standards within the framework of international agreements and (or);
countries or territories where there is a law on the confidentiality of financial information or companies are allowed to protect secrecy of the actual owner of the property or recipient of the income (profits).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.