Kazakhstan Tax Regime

Kazakhstan operates a source-and-residence corporate income tax system built around a flat 20% headline rate, layered with sector-specific rates for banking, gambling, agriculture and social services, and a distinct regime for extractive industries. The country's 2026 Tax Code — a wholesale rewrite that entered into force on 1 January 2026 — modernises administration, tightens rates for banks and gambling operators, and preserves special economic zone (SEZ) incentives and simplified regimes for small business. Kazakhstan's treaty network, transfer pricing rules and administration are shaped heavily by its position as a resource-exporting economy, with an excess profit tax and an alternative tax regime specific to subsurface users layered on top of the general corporate income tax.

1.1 Sources

1.2 Recent developments

On 18 July 2025 the President signed a new Tax Code that entered into force on 1 January 2026, restating the corporate and personal tax framework and introducing targeted rate changes. The CIT rate for banks (other than lending to businesses) and for casinos, slot-machine halls, totalizators and bookmakers rose to 25%. A reduced rate for entities operating in the social sphere was set at 5% for 2026, stepping up to 10% from 2027, while producers of agricultural products and aquaculture retain a 3% rate. Special economic zone exemptions, the excess profit tax regime for subsurface users and the alternative tax for Caspian and deep-formation oil and gas projects continue, with administration modernised under the new Code.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

The general corporate income tax (CIT) rate is 20%, assessed on a calendar-year basis. Resident legal entities are taxed on worldwide profits; non-resident companies operating through a permanent establishment (PE) in Kazakhstan are taxed only on profits attributable to that PE. Non-residents without a PE that derive Kazakhstan-source income are generally subject to withholding tax at source rather than assessment. Higher rates apply to specified sectors: 25% for banks (other than qualifying business lending) and for casinos, slot-machine halls, totalizators and bookmakers; 5% in 2026 (rising to 10% from 2027) for entities operating in the social sphere; and 3% for producers of agricultural products and aquaculture (fish farming). There are no regional or local income taxes.

A distinct branch profits tax applies to Kazakhstan permanent establishments of foreign legal entities: net income after the 20% CIT is subject to a further 15% branch profits tax, broadly equivalent to a deemed-dividend withholding on repatriated PE profits, subject to treaty reduction.

2.2 Dividends and participation

Dividends received by a Kazakhstan resident company from another resident company are generally exempt from further CIT where holding-period conditions are met, avoiding cascading taxation within domestic groups. Dividends received from qualifying long-term (three-year plus) holdings, including in listed securities via the local exchange, benefit from statutory exemptions. Outbound dividends to non-residents are subject to withholding tax (see section 4), subject to treaty relief and to exemptions for dividends distributed out of income already taxed under the excess profit tax or alternative tax regimes for subsurface users.

2.3 Income determination and deductions

Taxable income is computed as aggregate annual income less allowable deductions, following Kazakhstan financial reporting standards (IFRS or Kazakhstan national standards) as the accounting starting point, adjusted for tax rules. Business expenses incurred to derive income are generally deductible; fixed assets are depreciated by statutory pools at prescribed maximum rates, with accelerated double-rate depreciation available for certain newly commissioned fixed assets used in priority activities. Non-deductible items include unsupported or undocumented expenses, fines and penalties payable to the state, and expenses connected with non-deductible related-party arrangements. Value-added tax is generally excluded from the CIT base as a separate indirect tax.

2.4 Interest limitation

Deductibility of interest expense is restricted for related-party and other specified borrowings by a debt-to-equity and coverage-ratio test under thin-capitalisation rules: interest exceeding statutory ratios on debt owed to related non-residents and other specified lenders is non-deductible, with the disallowed portion potentially recharacterised as a dividend for withholding tax purposes. Interest paid to unrelated third-party lenders under arm's-length commercial loans is generally deductible in full, subject to general anti-avoidance and transfer pricing scrutiny.

2.5 Losses

Tax losses (the excess of deductions over aggregate annual income) may generally be carried forward for up to ten years and offset against future taxable income, subject to specific rules for losses arising from disposals of certain assets and securities, which may only be offset against gains of the same category. There is no loss carryback. Losses of subsurface users computed for excess profit tax purposes follow separate carryforward rules within that regime.

2.6 Group taxation

Kazakhstan does not operate a general fiscal consolidation or group-relief regime: each legal entity is taxed on a stand-alone basis and losses cannot be transferred between group companies. Intra-group transactions, financing and cost allocations remain subject to transfer pricing rules, and group restructurings are analysed under the general reorganisation and asset-transfer provisions of the Tax Code, which can provide continuity of tax attributes for qualifying statutory reorganisations (merger, consolidation, division, spin-off) between resident entities.

2.7 Controlled foreign companies

Kazakhstan applies controlled foreign company (CFC) rules attributing to a Kazakhstan-resident controlling person (holding, directly or indirectly, 25% or more, or 10% or more if Kazakhstan residents collectively hold over 50%) the undistributed profit of a foreign company or structure located in a jurisdiction with a low effective tax rate, subject to statutory exemptions including a de minimis profit threshold and exemptions for CFCs with substantive activity or in jurisdictions with which Kazakhstan has an effective exchange-of-information relationship and a comparable effective tax rate.

2.8 Transfer pricing

Kazakhstan's transfer pricing law applies the arm's-length principle to cross-border transactions and to specified domestic transactions (including with related parties benefiting from preferential regimes), broadly informed by OECD methodology. Taxpayers engaged in international business operations above statutory thresholds must maintain contemporaneous transfer pricing documentation and are subject to monitoring by the tax and customs authorities, with country-by-country reporting obligations for large multinational groups meeting the consolidated revenue threshold. Price adjustments can trigger both CIT and customs/VAT consequences given Kazakhstan's integrated monitoring of cross-border pricing.

2.9 Incentives

Investors in Kazakhstan's special economic zones (SEZs) — covering sectors such as petrochemicals, metallurgy, logistics, tourism and technology parks including the Astana Hub — may qualify for full CIT exemption, together with land tax, property tax and customs relief, subject to meeting statutory activity and investment conditions and location requirements. Investment tax preferences (accelerated depreciation, CIT and land/property tax exemptions for a limited period, and customs duty exemptions on imported equipment) are available under investment contracts for priority-sector projects outside SEZs. A simplified declaration regime and reduced rates support small business and agricultural producers.

2.10 Extractive industries — excess profit tax and alternative tax

Subsurface users are subject to CIT plus an excess profit tax (EPT) at progressive rates from 10% to 60%, levied on the portion of net income exceeding 25% of deductions computed for EPT purposes; EPT was abolished from 2018 for solid-mineral extraction contracts that do not also cover other mineral groups. A new Tax Code alternative tax, available at taxpayer election, substitutes for EPT, mineral extraction tax and historical-cost compensation for production or combined exploration-and-production contracts located fully within the Kazakhstan Caspian Sea sector or in deeply folded oilfields meeting specified depth criteria; the alternative tax rate is progressive from 0% to 42% generally (3% to 14% for complex marine projects) and tracks world crude prices, with foreign-exchange effects and interest deductions excluded from its base. Electing taxpayers can also be exempt from export rent tax on crude oil.

2.11 Pillar Two

Kazakhstan has not yet enacted a Pillar Two global minimum tax regime (income inclusion rule, undertaxed profits rule or qualified domestic minimum top-up tax) for in-scope multinational groups. Kazakhstan-headquartered and Kazakhstan-based constituent entities of groups within the EUR 750 million consolidated revenue threshold nonetheless remain exposed to top-up taxation imposed by other jurisdictions that have implemented an income inclusion rule or undertaxed profits rule with respect to low-taxed Kazakhstan profits, including profits benefiting from SEZ or investment-contract exemptions.

2.12 Branch income and reorganisations

A Kazakhstan branch (permanent establishment) of a foreign legal entity is taxed at 20% CIT on profits attributable to the PE under the authorised approach, with the additional 15% branch profits tax applied to after-tax PE net income regardless of actual repatriation, subject to treaty reduction (commonly to 5–15%, with several treaties eliminating the branch tax entirely). Statutory domestic reorganisations of resident legal entities — merger, consolidation, division and spin-off — can proceed without immediate CIT triggering where statutory continuity conditions are satisfied, with carryover of tax attributes including fixed-asset tax values; cross-border reorganisations are analysed as disposals absent specific relief, so asset step-up and CIT/withholding consequences should be modelled before restructuring.

3.1 Residence and rates

Individuals present in Kazakhstan for 183 days or more in any consecutive 12-month period, or with a centre of vital interests in Kazakhstan, are generally treated as tax resident and taxed on worldwide income; non-residents are taxed on Kazakhstan-source income only. Personal income tax (PIT) was a flat 10% until 2025; under the 2026 Tax Code a progressive scale applies to most employment and business income — 10% on annual income up to 8,500 MCI and 15% on the excess — which remains low by regional standards. Dividend income received by resident individuals is generally taxed at 10%, though specified dividends from listed securities and long-held qualifying holdings can be exempt.

3.2 Employment income and benefits in kind

Employment income, including most cash and in-kind benefits provided by an employer, is subject to 10% PIT withheld by the employer at source through payroll. Standard deductions include mandatory pension contributions and, within limits, certain social and medical insurance amounts. Non-resident employees are taxed at 10% on Kazakhstan-source employment income, generally without the standard resident deductions, subject to treaty relief for short-term assignees meeting dependent-personal-services exemption conditions.

3.3 Social payments and payroll contributions

Employment income is subject to a package of statutory social payments in addition to PIT: mandatory pension contributions (10% employee-funded, with an additional employer contribution phased in), social tax and social contributions paid by the employer, and obligatory medical insurance contributions shared between employer and employee. These payroll charges, layered on top of the flat 10% PIT, materially increase the effective cost of employment beyond the headline personal tax rate and must be budgeted separately by employers.

3.4 Capital gains and investment income

Capital gains realised by resident individuals on the disposal of securities, participation interests and other property are generally included in taxable income and taxed at the flat 10% rate, subject to exemptions for gains on listed securities traded on the Kazakhstan Stock Exchange meeting specified conditions and for gains on qualifying long-held participation interests. Interest income received by individuals from Kazakhstan banks and specified debt securities is often exempt or taxed concessionally to encourage domestic savings, while foreign-source interest and gains are includible in worldwide taxable income for residents.

3.5 Inbound individuals

There is no separate wealth tax on individuals; however, individually owned residential and other property is subject to annual property tax at progressive rates, and vehicle owners pay an annual vehicle tax. Inbound assignees should confirm residence status under both domestic day-count rules and applicable treaty tie-breaker provisions, as double taxation exposure can arise where a treaty partner also asserts residence; foreign tax credit relief is available domestically for Kazakhstan residents on foreign-source income taxed abroad, subject to a per-country limitation.

Kazakhstan imposes withholding tax on Kazakhstan-source income paid to non-residents without a local permanent establishment, covering dividends, interest, royalties and specified service fees, generally at a domestic statutory rate of 15% (20% for payments to entities in jurisdictions on Kazakhstan's low-tax blacklist, unless treaty relief applies and substance is demonstrated). Kazakhstan's treaty network of around 55 conventions typically reduces dividend and interest withholding to 5–15% and royalty withholding to 10–15%, with relief generally requiring a valid tax residence certificate and, since recent tightening, beneficial-ownership and substance confirmations.

Relief at source under a treaty requires the non-resident recipient to submit a valid certificate of tax residence, and — since recent legislative tightening aimed at treaty shopping — a beneficial-ownership declaration confirming the recipient is not a conduit lacking economic substance. Where relief at source is not obtained, withholding applies at the domestic rate with subsequent refund available on application within the statutory limitation period. Kazakhstan applies the multilateral instrument's principal purpose test to treaty benefits under covered agreements.

5.1 General anti-avoidance and substance requirements

The Tax Code contains a general anti-avoidance rule empowering the tax authorities to disregard or recharacterise transactions and structures lacking business purpose or genuine economic substance, including artificial arrangements designed principally to obtain a tax benefit such as treaty relief or a preferential SEZ or investment-contract regime. Related-party transactions, including cross-border financing, management fees and cost-sharing arrangements, receive heightened scrutiny under both the transfer pricing rules and the general anti-avoidance rule.

5.2 Exchange of information and disclosure

Kazakhstan participates in the OECD Common Reporting Standard for automatic exchange of financial account information and in country-by-country reporting exchange for large multinational groups. The tax authorities maintain lists of jurisdictions with preferential tax regimes for purposes of the CFC rules, the low-tax withholding surcharge and enhanced transfer pricing documentation triggers. Kazakhstan has signed the OECD/G20 multilateral instrument, modifying its covered double tax treaties with a principal purpose test and, for several treaties, expanded permanent establishment definitions targeting the avoidance of PE status through fragmented or dependent-agent arrangements.

6.1 VAT

VAT is levied at a standard rate of 16% on the supply of goods, works and services in Kazakhstan and on imports, with zero-rating for exports and certain international transport, and exemptions for specified financial, medical, educational and land transactions. Mandatory VAT registration applies once cumulative annual turnover exceeds a statutory threshold (a minimum monthly wage-linked figure recalculated for 2026 under the new Tax Code); voluntary registration is available below the threshold. VAT returns are generally filed quarterly, with input VAT recoverable against output VAT for taxable activities, subject to documentary support and, for certain sectors, an electronic invoicing (ESF) requirement.

6.2 Excise, customs and other taxes

Excise duties apply to alcohol, tobacco, fuel, and certain vehicles, at specific rates per unit. As a member of the Eurasian Economic Union, Kazakhstan applies the EAEU common customs tariff and coordinated customs procedures to trade with non-EAEU countries, while trade within the union moves largely duty-free subject to rules of origin. Property tax is levied annually on the book or cadastral value of buildings and structures held by legal entities (generally 1.5%, with reduced rates for certain sectors) and on individually owned residential property at progressive rates. Land tax is assessed on landholders based on area and cadastral quality categories. There is no net wealth tax or estate/inheritance tax in Kazakhstan.

7.1 Filing, assessment and audit

The tax year is the calendar year. CIT returns are filed annually, generally by 31 March of the following year, with quarterly or monthly advance payment obligations for most taxpayers based on projected liability. Tax administration is carried out by the State Revenue Committee under the Ministry of Finance through territorial tax departments, with a risk-based selection methodology for field and desk audits. The general statute of limitations for tax assessment is five years, during which the tax authorities may reassess and taxpayers may amend declarations; extended periods can apply for transfer pricing adjustments and cases involving international tax evasion indicators.

7.2 Rulings, appeals and penalties

Taxpayers may request preliminary clarifications and, for significant transactions, advance rulings from the tax authorities, though a comprehensive binding advance pricing agreement regime remains more limited than in some OECD jurisdictions. Assessment disputes are appealable first to a higher tax authority or, since recent reforms, an independent appeals commission, and thereafter to the specialised administrative courts, with the possibility of further appeal to the Supreme Court on points of law. Penalties for underpayment, late filing and non-compliance with transfer pricing or CFC documentation obligations are set as a percentage of the tax shortfall, with interest accruing on late-paid tax; voluntary correction before an audit notice typically mitigates penalty exposure.

Large taxpayers under monitoring by the tax authorities face additional real-time reporting obligations, including electronic invoicing and, for certain sectors, digital labelling and traceability requirements for goods. Late payment attracts statutory interest calculated with reference to the National Bank refinancing rate, in addition to fixed-percentage penalties for the underlying compliance failure.

9.1 Entity choice

The limited liability partnership (LLP, Kazakhstan's equivalent of an LLC) is the standard vehicle for foreign investment, requiring no statutory minimum capital and offering flexible governance; a joint-stock company (JSC) suits capital-market or larger multi-shareholder ventures. Branches of foreign companies are permitted and are taxed on attributable profits at 20% CIT plus the 15% branch profits tax; a locally incorporated subsidiary avoids the branch tax but exposes distributed profits to ordinary dividend withholding instead. Representative offices may conduct only non-commercial liaison activities and are not subject to CIT on that basis, but risk requalification as a taxable PE if commercial activity is in fact carried on.

9.2 Structuring and incentives

Investors in priority sectors should evaluate SEZ location and investment-contract incentives early, as CIT, land tax, property tax and customs relief are typically conditioned on advance registration and investment commitments rather than retrospective claims. Subsurface users must model the interaction of CIT, EPT and (where eligible) the alternative tax regime, since the elective alternative tax can materially change the profile of tax paid across the commodity price cycle. Financing structures involving related-party debt should be tested against the thin-capitalisation ratios in section 2.4, and cross-border payments should be structured with contemporaneous residence and beneficial-ownership documentation to secure treaty relief at source rather than relying on refund procedures.

9.3 Worked effective-rate illustration

A Kazakhstan LLP in a non-preferential sector earns EBITDA of KZT 900,000,000, with depreciation of KZT 120,000,000 and interest expense of KZT 60,000,000 fully within the thin-capitalisation limits. Taxable income is 900,000,000 − 120,000,000 − 60,000,000 = KZT 720,000,000. CIT at 20% is KZT 144,000,000, giving an effective rate on taxable profit of 144,000,000 / 720,000,000 = 20.0%. If the after-tax profit of KZT 576,000,000 is fully distributed to a non-resident parent in a treaty jurisdiction with a 10% treaty dividend rate, withholding of KZT 57,600,000 applies, producing a combined burden on distributed profits of 144,000,000 + 57,600,000 = KZT 201,600,000 against pre-tax profit of KZT 720,000,000, an all-in rate of 28.0%. Had the same profit instead been earned through an unincorporated branch, the after-CIT amount of KZT 576,000,000 would additionally suffer the 15% branch profits tax of KZT 86,400,000 regardless of actual repatriation, producing a higher all-in burden absent treaty reduction of that branch tax.

9.4 Compliance

Expect electronic filing of CIT, VAT and payroll returns through the tax authority's online portal, mandatory electronic invoicing for VAT-registered taxpayers in most sectors, and — for subsurface users and large taxpayers under monitoring — enhanced real-time reporting. Transfer pricing documentation should be prepared contemporaneously for in-scope cross-border transactions, and CFC computations must be maintained annually for qualifying foreign holdings even where no distribution is made. Beneficial-ownership and substance documentation should be kept current to support treaty relief at source on outbound payments.