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).