The new Tax Code of Kazakhstan came into force on 1 January 2002 and replaced the Law on Taxes, numerous tax instructions and letters of the Ministry of State Revenues which had regulated the interpretation and application of Kazakhstan's international tax provisions, including tax treaties. This article reviews the rules in the Tax Code on the taxation of non-resident companies in Kazakhstan, analyses the general approach to interpreting tax treaties, and examines the principal changes made to interpreting and applying Kazakhstan's tax treaties.