Last modified: 06/01/2025 11:17

Corporate taxation

	Rate
Corporate income tax rate1	20%
Branch tax rate2	20% + 15% net profit tax
Capital gains tax rate 3	20%

1. All Kazakhstan legal entities (except public institutions and public secondary educational institutions) and branches of foreign legal entities are subject to corporate income tax. The tax rate for corporations is assessed for a calendar year.

Reduced CIT rates

A reduced CIT rate of 6% applies to the qualified agricultural income of legal entities producing agricultural products. 

In addition, taxpayers operating in special economic zones (SEZs) may enjoy full exemption from CIT if certain statutory requirements established for such benefits are met.

2. A non-resident legal entity operating in Kazakhstan via a permanent establishment (PE) or branch is also subject to branch profit tax on its net (post-tax) income.

3. Capital gains are subject to income tax. However, capital gains associated with the disposal of the following securities may be exempt from taxation in Kazakhstan: Government securities.

Residence: Residents of Kazakhstan are legal entities established in accordance with the legislation of the Republic of Kazakhstan, and (or) other legal entities whose place of effective management (the location of the actual management body) is located in Kazakhstan.

Basis: A resident of the Republic of Kazakhstan pays taxes on income from sources in the Republic of Kazakhstan and abroad. A non-resident pays taxes on income from sources in the Republic of Kazakhstan. A non-resident operating in Kazakhstan via a permanent establishment (PE) also pays taxes on income from sources outside the Republic of Kazakhstan related to the activities of such a permanent establishment. Residents and non-residents also pay other taxes and payments to the budget, as well as social payments when such obligations arise.

Taxable income: Taxable income (which is determined as difference between comprehensive annual income adjusted for amount required by the Tax Code and applicable deductions) less revenues and expenses provided for by the Tax Code, minus loss carryforwards, as well as taxable income of controlled foreign companies and permanent establishments thereof, is applied a 20% CIT.

Significant local taxes on income: There are no regional or local income taxes in Kazakhstan. Income taxable at source, save for non-residents’ income from Kazakhstan sources, is applied a 15% CIT to be deducted at source; Net income (income after CIT) of a non-resident legal entity operating in Kazakhstan via a permanent establishment is also applied an additional 15% CIT. Taxable income of controlled foreign companies and permanent establishments thereof, except for those which are incorporated/registered in tax haven countries is not less than 20%; Taxable income of controlled foreign companies and permanent establishments thereof incorporated/registered in tax haven countries is not less than 20%.

Alternative minimum tax: There is no alternative minimum tax The new Tax Code introduced an alternative tax that replaces EPT, mineral extraction tax (MET), and compensation of historical costs and may be applied at the discretion of a taxpayer. The alternative tax is applicable to subsurface use contracts on production and/or combined exploration and production of oil and gas products, the place of which should be: • fully located in the Kazakhstan sector of the Caspian Sea, or • at deeply folded oilfields locating not higher than 4,500 metres and with lowest point of bedding at 5,000 metres or lower. Generally, the calculation of the tax base, the tax period, and the deadlines are similar to the existing CIT framework, except for some specifics (e.g. foreign exchange impact should be disregarded, interest expenses are not allowed for deduction). The tax rate is progressive (from 0% to 42%) and depends on the world price fluctuations of crude oil. In addition, the taxpayers applying an alternative tax can be exempt from payment of rent tax on export of crude oil.

Taxation of dividends: Dividend income of a Kazakhstan resident company on inbound dividends is exempt from Kazakhstan taxation. Dividends from a Kazakhstan resident company to another Kazakhstan resident company are exempt from taxation, except for dividends paid by certain types of taxpayers. Effective from 1 January 2023, dividends paid on securities that, on the date of dividends’ accrual, are included in the official list of the stock exchange of the Republic of Kazakhstan should not be subject to exclusion from the taxable income, unless there is an active bidding process. The criteria for an active bidding process are as follows: • The value of transactions with these securities should be at least KZT 25 million per calendar month. Only executed transactions with securities are taken in account. • The number of transactions with these securities should be at least 50 transactions per calendar month. • The placement of securities through an IPO (Initial Public Offering) or SPO (Secondary Public Offering), or the number of securities in free circulation, is at least 10 (ten) percent of the total number of issued securities, excluding those repurchased by the issuer. The stock exchange of the Republic of Kazakhstan (‘KASE’, ‘AIFC’) should report on the Internet sources of information about securities that meet the established criteria no later than the 15th day of the month following the reporting quarter.

Capital gains: Capital gains are subject to ordinary CIT rates. An exemption is available for capital gains realised from the sale of shares and participation interests in Kazakhstan for legal entities or consortiums that are not engaged in subsurface activities and are held for more than three years. Capital gains from sale of shares/participation interest in subsurface users may be exempt from taxation in Kazakhstan if such subsurface users are engaged in further processing activities, under specific conditions. Effective from 1 January 2023, Kazakhstan individuals paying capital gain to non-residents could also be considered as tax agents for withholding tax (WHT) purposes.

Losses: Net operating losses may be carried forward for up to ten years. Loss carryback is not permitted under the Kazakhstan tax legislation.

Foreign tax relief: Foreign tax credit In general, the Kazakhstan Tax Code allows taxpayers to credit the foreign income taxes paid against the income taxes payable in Kazakhstan, provided the documents confirming the payment of such taxes are available. However, a tax credit may not be granted in certain cases (e.g. for taxes paid in countries with privileged taxation).

Participation exemption: There is no participation exemption

Holding-company regime: There is no holding company regime.

Tax-based incentives: Certain incentives are available in the form of accelerated tax deductions for capital expenditure, provided certain requirements are met. There also are incentives for investments in priority economic sectors relating to business in special economic zones, and investments in qualifying investment priority projects. In addition, special tax regimes/incentives are available for qualifying nonprofit organizations and organizations operating in social spheres.

Investment incentives

Investment incentives are available to certain Kazakhstan legal entities that fit certain criteria and possess objects (e.g. certain fixed assets) for which investment incentives may be applied. Generally, the investment incentives allow companies to fully deduct, for CIT purposes, the cost of the investment objects and the cost associated with their reconstruction and modernisation either at once or within the first three years of their use.

Based on the Entrepreneurial Code, incentives are granted under an investment contract between the government and companies with focus on priority sectors of the economy, as determined by the government. A qualifying investment project is granted with (i) exemption from customs duties and import VAT exemptions, with some limitations, and (ii) state in-kind grants. Priority investment projects, alongside the above-mentioned benefits, get (iii) tax incentives and (iv) investment subsidies. Special investment projects in the form of investment preferences are granted with (v) exemption from custom duties and (vi) tax incentives.

The amendments to the Tax Code introduced an ‘investment tax credit’ that allows changing tax payment deadlines for certain categories of taxpayers and also allows them to reduce tax payments by 100% or pay tax due in instalments, provided certain criteria of the taxpayer is met. The investment tax credit can be provided for a period of up to three years.

From 2022, a stable tax regime for ten years may be provided under a new investment incentive envisaged by the Entrepreneurial Code (‘Agreement on investment obligations’) in return for certain obligations to be fulfilled by a taxpayer. Guarantee of taxation regime stability is provided for VAT, WHT, payroll tax, excise taxes, and payments for emissions to the environment.

Special economic zones (SEZs)

Currently, the following SEZs have been established in Kazakhstan:

• ‘Astana, the New City’ in Nur-Sultan (the expiry date is in 2027).

• ‘Aktau Sea Port’ in Aktau (the expiry date is on 1 January 2028).

• ‘Ontustik’ in Sairam district of South-Kazakhstan region (the expiry date is on 1 July 2030).

• ‘National Industrial Petrochemical Park’ in Atyrau region (the expiry date is on 31 December 2032).

• ‘Park of Innovative Technologies’ (the expiry date is 1 January 2028).

• ‘Saryarka’ in Karaganda region (the expiry date is 1 December 2036).

• ‘Horgos – the eastern gates’ in Almaty region (the expiry date is 2035).

• ‘Pavlodar’ in Pavlodar (the expiry date is 1 December 2036).

• ’Chemical Park Taraz’ in Taraz (the expiry date is 1 January 2037).

• ‘International Center for Cross-Border Cooperation Horgos’ in Almaty region (the expiry date is 1 January 2041).

• ‘Turkestan’ in Turkestan region (the expiry date is 1 January 2043).

• ‘Astana-Technopolis’ in Astana (the expiry date is in 2042)

• ‘Qyzyljar’ in Petropavl (the expiry date is in 2044)

In order to enjoy the incentives available in SEZs, a legal entity must meet the following requirements:

• It must be registered by the tax authorities in the territories of SEZs.

• It has no structural subdivisions beyond the boundaries of the territories of the SEZs.

• It must perform activities qualified for priority types of activities within the territory of an SEZ (activities performed by a participant of the SEZ ‘Park of Innovation Technologies’ may be performed on an extraterritorial basis).

The general incentives available for legal entities in SEZs are: • CIT: 100% reduction (subject to certain conditions). • VAT: 0% rate (for goods fully consumed during the performance of activities corresponding to purposes of creation of the SEZ and included in the list of goods established by the government of Kazakhstan). • Land tax and payment for the use of land plots: 0% rate. • Property tax: 0% rate. • Social tax: 100% reduction (subject to certain conditions for ‘Park of Innovative Technologies’).

The period of applying reduced amounts of taxes and (or) fees by 100 percent depends on the categories and their costs of projects established on special economic and industrial zones:

• category A – project cost up to 3,000,000 MCI (USD 6,700) – for 7 years;

• category B – project cost from 3,000,000 MCI (USD 6,700) to 14,500,000 MCI (USD 32,400) – for 15 years;

• category C – project cost from 14,500,000 MCI (USD 32,400) – for 25 years.

Astana International Financial Centre (AIFC)

The AIFC aims to create favourable conditions for investment and finance and to develop the securities market, ensuring its integration with international capital markets. The AIFC also intends to develop insurance, banking, and Islamic finance markets in Kazakhstan. The AIFC seeks to become a financial hub for the Central Asian region, member states of the Eurasian Economic Union, the Caucasus, Western China, the Middle East, Mongolia, and Europe.

The AIFC provides a special legal regime based on the principles of English law, independent financial regulation in accordance with international standards, tax preferences for a period of 50 years, simplified visa and labour conditions, and has English as an official language. Judges of AIFC`s Court have exclusive jurisdiction over disputes between the AIFC’s participants.

Group relief/fiscal unity: Kazakhstan tax law does not permit group taxation.

Small company/alternative tax regimes: Various small companies may qualify for special tax regimes specifying lower tax rates. The Tax Code provides for the following special tax regimes: Patent-based STR Mobile app-based STR STR based on a simplified declaration STR based on a fixed deduction the retail tax STR STR for farming enterprises (single land tax payers) STR for agricultural producers and agricultural cooperatives

Corporate taxation: compliance

Tax year: The tax year in Kazakhstan is the calendar year.

Consolidated returns: Consolidated returns are not permitted; each company must file a tax separate return. However, non-residents with several PEs in Kazakhstan may opt to file a consolidated tax return.

Filing and payment: Tax returns Annual CIT declarations are due by 31 March of the year following the tax year-end. However, a taxpayer may take a 30 calendar-day extension of the deadline upon request. Certain taxpayers are required to submit their estimated calculations of monthly advance payments of CIT. The deadline for the majority of other tax returns is the 15th calendar day of the second month following the reporting period (usually the calendar quarter). However, a taxpayer may take a 15 calendar-day extension of the deadline upon request. Payment of tax CIT advance payments are due every 25th day of the month. Taxpayers with aggregate annual income during the tax period preceding the previous tax period of less than 325,000 times the MCI established for the relevant financial year (approximately USD 2.2 million) are exempt from the obligation to calculate and pay CIT advance payments. Payment of any outstanding CIT liabilities is required within ten calendar days following the submission of the annual CIT declaration (i.e. 10 April). Most other taxes are payable by the 25th day of the second month following the end of the reporting period (calendar quarter).

Penalties: Fines and interest penalties Late payment interest is calculated at 1.25 times the base rate set by the National Bank per day of delay. Starting from 2 December 2024, the National Bank base rate has been set at 15,25% per annum. Substantial fines are imposed for understatement of tax liabilities. Generally, the fines amount to 80% of the understated tax, with lower rates for small and medium-sized businesses. For advance CIT payments, an administrative fine of 20% applies for understated advance tax payments as compared to the finally declared CIT, provided the understated amount is greater than 20% of the final declared amount. If a taxpayer is deemed to have concealed taxable income, a fine of up to 200% of the concealed amount may be assessed. Small and medium-sized businesses have lower rates.

Rulings: The tax authorities generally issue nonbinding rulings of an explanatory nature. However, rulings issued by the tax authorities individually to taxpayers shall be considered during the tax appeal process. Advance pricing agreements are also possible.

Taxation of individuals

	Rate
	Federal Income Tax
A single flat rate for both residents and nonresidents	10%
Dividends for residents	5%
Dividends and capital gains for non-residents	15%
Other income for residents	10%
Other income for non-residents	20%

Residence: Tax residents are defined as individuals who permanently reside in Kazakhstan or have their centre of vital interests in Kazakhstan even if they do not permanently reside in Kazakhstan during the reporting year.

Kazakhstan tax residents

A Kazakhstan tax resident will be an individual who has spent 183 or more days in Kazakhstan within any 12-month rolling period ending in the relevant year (including days of arrival and departure) or who has spent less than 183 calendar days in any 12-month rolling period but whose centre of vital interest is located in Kazakhstan during that year.

The centre of vital interest is deemed as located in Kazakhstan if the following criteria are simultaneously met during the reporting year:

• An individual held Kazakhstan citizenship or a residence permit.

• An individual’s family and (or) close relatives lived in Kazakhstan.

• An individual and (or) one’s family members owned real estate in Kazakhstan that was available for the individual’s and (or) one’s family members at any time.

Tax residents are liable for reporting and paying tax in Kazakhstan for worldwide income and Kazakhstan-source income that is not taxed at the source via self-assessment (Tax Form 240.00). Submission of Tax Form 240.00 is by 31 March of the year following the reporting one and settlement of tax liability by 10 April.

However, starting from 2021, if an individual falls under the categories that are defined by the newly introduced Universal Filing Law, this individual should submit the universal filing tax forms.

Besides tax liabilities described above, tax residents, who are Kazakhstan citizens / residence permit holders, are required to disclose funds (in excess of approximately 15,000 United States dollars [USD] in total) on foreign bank accounts and information on ownership of property / securities / participation share located outside of Kazakhstan and digital assets as of 31 December of the reporting period (for information purposes only).

Kazakhstan tax non-residents

A Kazakhstan tax non-resident is: • an individual who does not fall under the definition of a ‘Kazakhstan tax resident’ (please refer to the above listed criteria), or • a foreign citizen or individual without citizenship recognised as non-resident in accordance with an effective double tax treaty (DTT). Under the Tax Code requirements, a certificate of foreign tax residency should be provided by the tax return filing deadline (i.e. 31 March of the year following the reporting one). It should be properly legalised (apostilled) and a notarised translation into Russian/Kazakh should be enclosed. Kazakhstan tax non-residents are required to file the annual individual income tax return reporting Kazakhstan-source income that was not subject to taxation at source of payment during the reporting year, (e.g. capital gain, dividend, interest, property income, rental income).

Basis: Resident individuals are taxed on worldwide income. Non-residents are taxed only on their Kazakh-source income.

Taxable income: Kazakh-source income includes income from employment and other activities in Kazakhstan and any other benefits received in this respect, regardless of where payment is made. Taxable income is comprised of employment income (including benefits in kind), income from a business, income from third parties (including that received free of charges) and passive income. Local legislation provides for certain exemptions depending on the type of income and the individual’s circumstances.

Capital gains: Capital gains of the resident is subject to income tax at the rate 20%. Capital gains received from a Kazakhstan source are subject to income tax at the rate of 15%. However, capital gains associated with the disposal of the following securities may be exempt from taxation in Kazakhstan: • Government securities. • Agency bonds. • Securities listed at the day of disposal on the stock exchange operating in Kazakhstan (if sold by the method of advertised bidding on such stock exchange). • If all of the following conditions are met:  On the date of sale, taxpayer owns shares for more than three years.  Company whose shares are sold is not regarded as a subsurface user.  More than 50% of company whose shares are sold is not owned by subsurface user(s).

Deductions and allowances: Standard monthly deductions are allowed for tax residents, such as a minimum monthly tax deduction, deductions for mandatory pension fund contributions, social medical insurance contributions, and deduction for voluntary pension contributions, medical costs, etc., with certain limitations. Starting 1 January 2025, the general standard tax deduction is based on 14 times the MCI (1 MCI = KZT 3,932; 14 MCI = KZT 55,048) or KZT 660,576 per annum, which is applicable to Kazakhstan tax residents.

Foreign tax relief: Kazakhstan tax residents are allowed to claim a tax credit in Kazakhstan against taxes paid abroad on their foreign-source income. In order to claim a tax credit in Kazakhstan for the amount of taxes paid abroad, an individual should provide a legalised (apostilled) certificate on income received and taxes paid abroad during the reporting period, issued or certified by the foreign tax authorities. This certificate should be on hand at the moment of submission of the annual tax return (i.e. by 31 March of the year following tax reporting one). Also, a notarised translation to Russian or Kazakh language should be enclosed.

Taxation of individuals: compliance

Tax year: The tax year in Kazakhstan is the calendar year.

Filing and payment: Tax returns Tax agents are required to file quarterly payroll tax reports (Declaration on Individual Income Tax and Social Tax, jointly for Kazakhstan citizens, foreigners, and individuals working on a Civil Contract basis) in respect of income paid/assessed to its employees/individuals and respective payroll taxes/contributions withheld at source or paid accordingly. The statutory deadline for submission of payroll tax reports is the 15th day of the second month following the reporting quarter (15 May, 15 August, 15 November, and 15 February).

There is also a self-assessment system whereby all taxpayers who have income from Kazakhstan and other sources that is non-taxable at source (in the absence of a tax agent) are required to submit an annual declaration on individual income tax by 31 March of the year following the reporting year.

Universal declaration The first stage of universal filing was introduced in Kazakhstan for individuals starting with governmental employees in 2021, employees of the quasi-public sectors in 2023, heads and founders of legal entities in 2024. Listed individuals are required to adhere to the legal mandate of submitting universal tax forms. They must file the “Declaration on Assets and Liabilities” (Form 250.00) along with the “Declaration on Income and Property” (Form 270.00).

These forms ensure compliance with tax regulations by providing a detailed account of an individual’s financial status. Form 250.00 is a one-time form for reporting accumulated assets and liabilities as entry information related to the integration of the mandatory universal filing system.

Form 270.00 is a form that is submitted annually after Form 250.00, in which individuals should report income and property received during the reporting period. However, if an individual would like to claim a foreign income tax credit, the declaration on individual income tax Form 240.00 should be filed as well.

The submission deadline for Form 250.00 and Form 270.00 is тo later than 15 September of the year following the reporting. The tax payment deadline is 10 days after the submission date.

Payment of tax Tax agents withhold income tax no later than the date of income payment to the individual. Tax is due prior to the 25th day of the month following the month of payment. In case of self-assessment, individual income tax should be paid within ten calendar days after the official deadline for the annual tax return submission (i.e. by 10 April). If the deadline falls on the weekend, it will generally be scheduled for the following Monday.

Penalties: Penalties apply for late payment of taxes, and administrative fines are imposed for noncompliance. Penalties are assessed at 1.25 times the official base rate established by the National bank on the tax unpaid for each day of delay in paying the tax due. The current Code on administrative violation provides that an individual who has filled a tax return late for the first time will receive an administrative warning; a fine of 15 times the MCI will be imposed for subsequent violation.

Rulings: The Tax authorities generally issue nonbinding rulings of an explanatory nature. However, rulings issued by the Tax authorities individually to taxpayers will be considered during the tax appeal process.

Withholding taxes

Type of Payment	Resident recipients		Non-residents recipients
	Company	Individual	Company	Individual
	Rate (%)	Rate (%)	Rate (%)	Rate (%)
Dividends, capital gains, interest, royalties1	0	0	15%	0
Insurance premiums under risk insurance agreements	0	0	15%	0
Income from international transportation services; insurance premiums under risk reinsurance agreements	0	0	5%	0
Any income of a ‘black-listed’ entity	0	0	20%	0
Other income, including income from the provision of services 2			20%

1. WHT on dividends

Effective from 1 January 2023, income of a non-resident in the form of dividends shall be taxable at the reduced rate of 10% if the following conditions are simultaneously met:

• dividends are not paid to the entities registered in the ‘black-listed’ jurisdictions
• the holding period of shares or participation interest is greater than three years (this should include the holding period by a previous holder if such shares/participation interest were received as a result of reorganisation of a previous holder)
• the entity paying the dividends is not a subsurface user, and
• 50% or more of the value of the entity paying the dividends is not derived from property of a subsurface user.

Herewith, dividend income of a non-resident paid by a subsurface user should qualify for 10% WHT exemption (provided all the above conditions are met) if such subsurface user is engaged in further processing activities, under specific conditions.

It should be noted that the reduced 10% WHT rate applies only to dividends paid from net income that was previously subject to CIT, which is determined as the difference between the amount of taxable income and the amount of CIT calculated. 

Income previously subject to CIT is determined for each tax period for which dividends are distributed.

         WHT on capital gains

A non-resident legal entity is exempt from WHT on capital gains if the following are met simultaneously:

• capital gains are not paid to the entities registered in the ‘black-listed’ jurisdictions
• the holding period of shares or participation interest is greater than three years (this should include the holding period by a previous holder if such shares/participation interest were received as a result of reorganisation of a previous holder)
• the entity from which the shares/participation interest are disposed is not a subsurface user, and
• 50% or more of the value of the entity from which the shares/participation interest are disposed is not derived from property of a subsurface user.

Herewith, capital gains of a non-resident that directly or indirectly disposes of shares/participation interest of a Kazakhstan subsurface user should qualify for WHT exemption (provided all above conditions are met) if such subsurface user is engaged in further processing activities, under specific conditions.

      2. WHT on certain types of activities

Income of non-residents from provision of services in Kazakhstan is subject to WHT at 20%, including certain types of services (management, financial, consulting, engineering, marketing, auditing, and legal) that are deemed as Kazakhstan-sourced income disregarding the place of their actual performance.

3.  The rate of WHT may be reduced/non-resident’s income may be exempted under an applicable DTT (double taxation treaties), provided that the following conditions are met simultaneously:

• Existence of bilateral DTT ratified by both parties.
• The non-resident does not create a PE in Kazakhstan.
• The non-resident timely provides to a Kazakhstan tax agent the qualifying tax residency certificate (the Tax Code provides for additional document requirement in case the non-resident provides services in Kazakhstan). According to amendments to the Tax Code, duly formalised tax residency certificates can be provided in e-format provided all signatories and stamps are available on the corresponding website from 1 January 2019.
• The non-resident is a beneficial owner of passive income (i.e. dividends, interest, or royalty) paid by a Kazakhstan tax agent.
• In case of active income paid by the tax agent to a related non-resident, one of the following conditions is met:
  • If the DTT between Kazakhstan and the relevant state of the non-resident is not affected by the MLI (Multilateral Instrument) , the non-resident is a beneficial owner of such income.
  • If the DTT between Kazakhstan and the relevant state is affected by the MLI, the non-resident’s income is subject to inclusion into the non-resident’s taxable base with no exemption/adjustment of taxable income or refund of tax paid from such income, and the relevant nominal tax rate in the state of the non-resident is not less than 15%.

Starting from 1 October 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) entered into force in Kazakhstan. This means that MLI provisions should affect covered DTTs, on which both contracting states deserved to extend the MLI. Kazakhstan expressed intention to extend some of the MLI provisions to all its DTTs conducted with the MLI member states. Certain DTTs are affected by MLI provisions from 1 January 2021.

One of the main MLI provision that may impact application of treaty relief to a non-resident’s income is the principal purpose test, which denies treaty benefit if, notwithstanding any provisions of the DTT, it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the DTT.

Effective from 1 January 2023, if dividend, interest, and (or) royalties are paid to a related party who is a resident of a country with which the DTT has been amended by the MLI, the tax agent has the right to apply the DTT provisions if income is included in the taxable income of a non-resident recipient and is subject to tax at the nominal tax rate not less than 15%.

Branch remittance tax: A net profit tax applies. A PE of a nonresident foreign company is subject to a net profit tax of 15% on net after-tax income, in addition to corporate income tax. The net profit tax is payable regardless of whether net profits are “remitted” to the parent company. The tax rate may be reduced in line with the corresponding provisions of an applicable tax treaty in force with Kazakhstan.

Anti-avoidance legislation

Transfer pricing: Under the Kazakhstan transfer pricing law, tax authorities have the right to monitor and adjust prices used in cross-border and certain domestic transactions when prices are perceived to deviate from market prices, even if such transactions are with unrelated parties. If the authorities adjust prices, the re-assessed liability will include taxes, duties, penalty interest, and fines to the state budget. Transfer pricing rules impact the following transactions: • International commercial transactions. • Domestic transactions that directly relate to international commercial operations where: – the sale relates to a subsurface use contract – either party to the transaction has tax preferences, or – one of the parties has losses for two years preceding the year of the transaction. Country-by-country (CbC) reporting From 2018, the Transfer Pricing law introduces a 3-tiered approach to transfer pricing documentation for multinational enterprise (MNE) groups conducting business in Kazakhstan to file a CbC report retrospectively from January 2016, and a Master file and a Local file from January 2019, with the Kazakhstan tax authorities. Kazakhstan entities of MNE groups are required to submit a notification about being a member of an MNE group not later than 1 September before the reporting financial year. Non-compliance with the above requirements will lead to penalties.

Interest restriction: Deduction of interest paid to related parties, to unrelated parties under related parties warranties, or to parties registered in countries with privileged taxation depends on the borrower’s capital structure; deductible interest will be limited with reference to an ‘acceptable’ proportion of debt-to-equity (7:1 for financial institutions, 4:1 for all other entities). The list of jurisdictions with privileged taxation, the so called ‘black list’ established by the government, includes 56 jurisdictions.

Controlled foreign companies: According to the Tax Code, a CFC is deemed to be an entity that meets both of the following conditions: • 25% or more of a non-resident’s shares belong directly, indirectly, or constructively to a Kazakhstan entity, or the entity is connected with the resident by means of control, and • the effective income tax rate of the non-resident is less than 10% or the non-resident is registered in a ‘black-listed’ jurisdiction (see above). Recent amendments to the Tax Code introduced retrospective changes to the definition of a CFC, which now excludes companies registered in countries with an effective DTT with Kazakhstan if the nominal CIT rate in such country is more than 15%. In addition, the new amendments introduced a de minimis threshold (150,495 times MCI) for aggregate income of a CFC that should not be registered in a black-listed jurisdiction. This allows for the exemption of such company from Kazakhstan CFC rules. The consolidated profit of the CFC (and PE of the CFC) should be included in the taxable income of the Kazakhstan entity and subject to CIT on the portion of undistributed profits from the non-resident company. Amendments to the Tax Code also introduced exclusion of the company that bears financial loss indicated in its approved separate non-consolidated financial statement from the definition of CFC with retrospective effect starting from 1 January 2018. In addition, the Tax Code provides for elimination of double taxation of the CFC’s financial profit (subject to certain criteria).

Hybrid mismatches: No

Disclosure requirements: Tax residents (both individuals and legal entities) must notify the Kazakh Tax authorities of a direct, indirect, or constructive participation in (control over) a CFC. A notification of participation in an MNE group may be required to be filed by qualifying MNE group members subject to CbC reporting requirements (see Transfer pricing above).

Exit taxes: No

General anti-avoidance rule: No

Digital services tax and Other significant anti-avoidance legislation: Since April 15, 2022, an order of the Minister of Finance was put into effect in Kazakhstan on tracking mobile transfers of Kazakhstanis who have signs of receiving income from entrepreneurial activities

Value-added tax/Goods and services tax

Type of tax: Value-added tax (VAT) is applicable to the sales value of goods, works, and services, as well as to imports. Exports of goods and international transportation services are taxed at 0% VAT. There is a list of goods, works, and services exempt from VAT (e.g. sales of medicines, financial services provided by financial institutions, financial leasing services, notary and advocacy services, operations with financial securities and investment gold, loan transactions).

Standard rate: 12%

Reduced rates: 0%

Registration: The obligatory VAT registration threshold in 2025 is set at 20,000 times the Monthly Calculation Index (MCI). For individual entrepreneurs using special tax regimes, the VAT threshold is set at 144 184 times the MCI.

Filing and payment: The VAT reporting period is a calendar quarter. Payment is due by the 25th day of the second month following the reporting quarter. VAT and related turnover should be reported on a quarterly basis, by the 15th day of the second month following the reporting quarter.

All VAT payers should issue VAT invoices in electronic format (‘e-invoices’). VAT payers issuing e-invoices who are involved in sales of certain types of goods (specifically listed in the order of the Ministry of Finance) should register these goods within the Virtual Warehouse (VW) module. If such goods are not in the VW module, their sale is impossible, as the e-invoicing information system prevents a taxpayer from issuing an e-invoice for goods that are not recognised in the VW module.

A new clause in the Tax Code from 2022 introduces the notion of ‘traceability of the turnover of goods imported into the customs territory of the Eurasian Economic Union (EAEU or EEU)’. The national traceability system would be the electronic invoice information system. E-invoice is an accompanying document of the national tracing system. The tax authorities should ensure provision of data on goods subject to tracing and associated turnover transactions contained in the E-Invoicing System to the respective EAEU states.

Since 2022, issuance of e-invoices is not required upon sale of (i) goods from the list of exclusions, (ii) imported goods, and (iii) goods of non-VAT payers reflected in a VW module if such goods are sold to:

• individuals using purchased goods for own, family, home, or any other purposes not related to business operations, or • individuals or legal entities being subjects of micro-entrepreneurship. I

n addition, Kazakhstan launched a pilot project for issuance of e-waybills on importation, shipment, and export of goods from Kazakhstan. A different timeline of the pilot project is envisaged for different categories of goods.

From 2022, minimum prices apply to certain goods imported to Kazakhstan from the Eurasian Economic Union for determination of VATable import. Currently, the list includes only certain types of spirits and alcohol, but the list could potentially be amended in future.

From 2022, VAT on electronic sale of services and goods is introduced (the so-called ‘Google Tax’). The tax will be assessed and paid by foreign companies rendering services to Kazakhstan individuals in electronic format or by foreign companies owning Internet platforms through which Kazakhstan individuals purchase goods.

The payer of the VAT shall calculate the Google tax if one of the following conditions is met:

• The place of residence of the individual buyer is the Republic of Kazakhstan.

• The location of the bank in which the bank account is opened, used by the individual buyer to pay for services, or the electronic money operator through which the individual buyer pays for services is the territory of the Republic of Kazakhstan.

• The network address of the individual buyer used in the purchase of services is registered in the Republic of Kazakhstan.

• The international country code of the telephone number (including mobile) used to purchase or pay for services is assigned by the Republic of Kazakhstan. Issuance of invoices by the payer of Google tax is not required. A foreign company is required to pay the calculated Google tax for each quarter no later than the 25th day of the second month following the quarter in which the sale of goods and services was carried out.

Social security contributions

	Employer	Employee
	Rate (%)	Rate (%)
Payroll taxes 1	0	10%
Social tax2	11%	0
Social security contributions3 under employment agreement	5%	0
Social security contributions3 under civil contracts	0	5%
Obligatory pension contributions (OPC)4	2.5%	10%
Obligatory medical insurance contributions (OMIC)5	2%	3%

1. Payroll taxes

Employment income (salary, compensation, etc.) is subject to withholding individual income tax paid at source. Tax paid at source should be calculated, withheld, and remitted by the Kazakhstan company acting as a tax agent at the rate of 10%.

2. Social tax

Social tax is payable by employers in respect of employees (both locals and expatriates) at 9.5% on top of the employee’s gross remuneration.

The minimum limit for calculating social tax is 14 times the MCI * 9.5% (approximately USD 10).

3. Obligatory social contributions

Obligatory social insurance contributions are payable by employers at the rate of 5% to the State Pension Centre of Pension Payments. Obligatory social insurance contributions are capped at 5% of seven times the minimum monthly wage (MMW) (approximately USD 57) per month and are deductible from social tax. Only Kazakhstan citizens, foreigners holding a residence permit in Kazakhstan, and citizens of member countries (i.e. Russia, Belarus, Armenia, and Kyrgyzstan) of the Eurasian Economic Union (EAEU or EEU) who have a local employment agreement are subject to obligatory social insurance. Starting from January 1, 2025, social contributions will be withheld from the income of individuals performing work or providing services under civil contracts. This means that social contributions under service contracts will be withheld and paid from the incomes of individuals as mandatory pension contributions and social medical insurance.

4. Obligatory social medical insurance contributions

Starting from 1 January 2022, employer’s OMIC are increased to the rate of 3%. All employers, including branches and representative offices, should pay OMIC for all their employees, including Kazakhstan citizens and foreigners holding Kazakhstan residence permit, or citizens of member countries of the Eurasian Economic Union. The monthly income accepted for calculating deductions and contributions should not exceed ten times the minimum monthly wage (in 2025, the calculation of income is not more than 850,000 Kazakhstan tenge [KZT]; 2025 minimum monthly wage is KZT 85,000). 

And starting from 1 January 2021, employee’s OMIC are withheld at a rate of 2% out of employees’ gross income and paid to the Social Health Insurance Fund. The gross income subject to employee OMIC is capped at 10 times the MMW per employee per month. Subject to employee OMIC are Kazakhstan citizens, foreigners holding Kazakhstan residence permit, and citizens of member countries of the Eurasian Economic Union.

5. Obligatory pension contributions (OPC)

OPC are withheld at a rate of 10% out of employees’ gross income and paid to the State Pension Centre of Pension Payments. The gross income subject to OPC is capped at 50 times the minimum monthly wage MMW (approximately USD 8,173) per employee per month. Only Kazakhstan citizens, foreigners holding a residence permit in Kazakhstan, and citizens of member countries of the Eurasian Economic Union, who have a local employment agreement, are subject to OPC.

In addition, individuals who are working under a service agreement (providing services on a Civil Contract basis) should not make OPC to the State Pension Centre in their own favour. Starting from 2019, OPC for these individuals should be done by a tax agent (company with which the contract is concluded).

Obligatory Employer Pension Contributions (OEPC)

Starting from 1 January 2024, the employer shall pay OEPC at the rate of 1.5%. Income accepted for calculating the OEPC includes all types of wages in monetary terms and other income. At the same time, the monthly income accepted for calculating the OEPC must be no less than the MMW and must not exceed 50 times the MMW established for the corresponding financial year by the law on the republican budget. Exempt from paying OEPC are individuals who have reached retirement age, individuals with disabilities of the first and second groups, military personnel, employees of special government and law enforcement agencies, and individuals over 48 years of age.

Obligatory Professional Pension Contributions (OPPC)

The employer is required to allocate 5% of one’s own resources as OPPC to the employees engaged in jobs with harmful (especially harmful) work conditions. The list of positions subject to OPPC is published by the authorised state authority. Income accepted for calculating the OPPC includes all types of wages in monetary terms and other income. At the same time, the monthly income accepted for calculating the OPPC must be no less than the MMW and must not exceed 50 times the MMW established for the corresponding financial year by the law on the republican budget.

Self-employed

The Unified Tax Payment (UTP) in Kazakhstan, introduced on January 1, 2023, is a comprehensive tax mechanism that consolidates several taxes and social payments. These include individual income tax, mandatory pension contributions (both employee and employer portions), social contributions, and mandatory social health insurance contributions. This tax regime is designed to simplify the tax payment process and reduce the fiscal burden on the payroll funds for businesses, particularly benefiting micro and small enterprises and individual entrepreneurs operating under special tax regimes like the simplified declaration, retail tax, and agricultural producers. For 2025, the rate for the Unified Tax Payment is set at 23.8% of the payroll fund, with a planned gradual increase each year. Payments are due monthly, by the 25th day of the following month. Self-employed Kazakhstanis can either register as an individual entrepreneur and choose a special tax regime, or annually submit a separate declaration on individual income tax and pay 10% of their income.

Other taxes

Capital duty: No

Immovable property taxes: Property tax is assessed annually at a general rate of 1.5% of the average net book value of immovable property. Property tax objects include buildings and constructions in actual use, even if not registered with the justice authorities.

Transfer tax: No

Stamp duty: No standalone stamp duty regime exists. However, the authorities may impose a levy on various legal actions, such as the issuance of documents by state bodies.

Net wealth/worth tax: No

Inheritance/gift taxes: No

Other: Excise taxes Excise taxes apply to the sale and import of crude oil, gas condensate, petrol/gasoline (excluding aviation fuel), diesel fuel, spirits and alcoholic beverages, beer, tobacco, and passenger cars.

Type of Excisable Good and Corresponding Excise Tax Rates:

Crude Oil, Gas Condensate, Petrol/Gasoline, Diesel: The excise tax rate ranges from KZT 0 to KZT 38,134 per tonne. Alcoholic Beverages and Beer, Tobacco: Rates vary from KZT 0 to KZT 15,900 per unit of measure (kilograms, liters,

or individual items). Passenger Cars:

The excise tax is KZT 100 for each cubic centimeter of engine capacity.

Land tax

Entities and individuals that own land plots (or land share in cases of commonly shared ownership of land plots) must pay land tax annually. Land tax rates vary based on the purpose for which the land is used, as well as the size and quality of the land.

Vehicle tax

Vehicle tax rates are based on MCI and determined in accordance with the type of vehicle, engine volume, operation period of vehicles (aircraft only), and other factors.

Mineral extraction tax (MET)

MET applies to the monetary value of extracted volume of crude oil, gas condensate, natural gas, minerals, and groundwater.

MET is calculated based on the value of the extracted content, which is computed by applying average global prices to the extracted volume (adjusted for content). The determination of average global prices is based on the list of publications that are considered as official sources for computation of MET (Platts Crude Oil Marketwire and Crude Argus).

Currently, MET rates for crude oil and gas condensate range from 3% to 18%, depending on the accumulated production volume for the calendar year. For hydrocarbons, rates can be reduced by 50% if they are supplied to domestic refineries on the basis of a sale/purchase agreement or tolling agreement.

The MET rate for natural gas is set at 10%. For domestic sales of natural gas, MET rates range from 0.5% to 1.5%. MET rates for minerals that have undergone initial processing (except for widespread minerals) and for coal vary between 0% and 21.06%%. The amendments to the Tax Code introduced a maximum MET rate of 1 MCI per cubic metre under certain conditions, as well as other reduced rates for specific cases, which simplifies the administrative procedure of tax liability calculation, with retrospective effect starting from 1 January 2018. The application of MET rates effective as of 31 December 2022 is possible if the field of solid minerals is classified as low profit (5% or less). The criteria for providing incentives for exemption from MET for new fields with a link to the level of the internal profitability rate were introduced.

Tax treaties

Kazakhstan has concluded 53 international tax treaties on double taxation avoidance.