2. REQUIREMENTS FOR SUBSTANTIAL PRESENCE ON THE TERRITORY OF THE CENTRE

6) The Centre Participant is recognised as substantially present on the territory of the Centre, if the Centre Participant simultaneously fulfils the following conditions:

1. 1.The Core Income Generating Activities (hereinafter, CIGA) of the Centre Participant are provided on the territory of the Centre and consist of the services established by paragraphs 3 and/or 4 of Article 6 of the Constitutional Law and/or Chapter 3 of the List of Financial Services.
2. 2.The amount of operating expenses incurred by the Centre Participant must correspond to the adequate amount required for performing of the CIGA.
3. 3.The number of qualified full-time employees of the Centre Participant must correspond to the adequate number required for delivery of the CIGA.

7) The Centre Participants must submit to the local state revenue authority an economic study of the project, including the justification of costs and the number of employees.

8) The procedure for determination of compliance of the Centre Participant with the conditions established by this Chapter is determined by the state revenue authority during a tax audit. The level of adequacy of the number of full-time employees and the volume of expenses incurred is determined by identical types of activities of similar operating industries.

9) In case of a Centre Participant’s non-compliance with the conditions provided in these Rules the taxation procedure established by the Tax Code of the Republic of Kazakhstan is applied.