Corporate Income Tax Structuring

Advising on the corporate income tax (CIT) position of foreign-invested Kazakhstani entities — standard CIT rate, reduced rates for qualifying activities, investment incentive exemptions, and the interaction between the new Tax Code No. 214-VIII and existing investment contracts. Bond Stone advises on structuring the investment entity to optimise the CIT position within the legal framework.

Withholding Tax & DTT Planning

Advising on withholding tax on dividends, interest, and royalties paid to foreign shareholders — standard rates under the Tax Code and reduced rates under Kazakhstan’s 50+ double taxation treaties. Bond Stone advises on treaty eligibility, beneficial ownership requirements, and the documentation required to apply a reduced treaty rate at source.

Transfer Pricing

Advising on transfer pricing rules applicable to related-party transactions between a Kazakhstani subsidiary and its foreign parent — the arm’s length principle, deductibility of related-party payments, thin capitalisation rules limiting interest deductibility, and transfer pricing documentation requirements. Bond Stone advises on structuring intercompany transactions to comply with Kazakhstani transfer pricing rules.

VAT — Investment Transactions

Advising on VAT implications for foreign investors in Kazakhstan — 16% standard VAT rate (from 1 January 2026), import VAT, VAT on services received from foreign suppliers (reverse charge), VAT refunds on construction costs under Investment Priority Project contracts, and VAT exemptions within Special Economic Zones under the free customs zone procedure.

AIFC Investment Tax Residency

The AIFC investment tax residency regime provides qualifying individuals and legal entities with significant tax benefits — 0% CIT on qualifying income, 0% withholding tax on dividends paid by AIFC participants, and exemptions from certain other Kazakhstani taxes. Bond Stone advises on AIFC investment tax residency eligibility, application, and the structuring of investment activity to maximise available AIFC tax benefits.

Tax Code 2026 — New Framework

The new Tax Code No. 214-VIII dated 18 July 2025 entered into force on 1 January 2026 — replacing Tax Code No. 120-VI dated 25 December 2017. Bond Stone advises on the impact of the new Tax Code on existing investment structures, investment contracts, and tax incentive arrangements — and on the transitional provisions applicable to investments made under the previous Tax Code framework.

50+ bilateral double taxation treaties

Kazakhstan has concluded double taxation treaties with over 50 states including China, Germany, France, the Netherlands, Russia, UAE, UK, and USA. DTTs reduce or eliminate withholding tax on cross-border payments and address permanent establishment risk for foreign investors operating in Kazakhstan. Bond Stone advises on DTT applicability and the documentation required to access treaty benefits.

Beneficial ownership requirement

To access reduced DTT withholding tax rates, the recipient of the payment must be the beneficial owner of the income — not a conduit entity. Kazakhstan’s tax authority applies beneficial ownership analysis on dividend, interest, and royalty payments made to treaty partners. Bond Stone advises on structuring holding arrangements to satisfy beneficial ownership requirements under the applicable DTT.

Permanent establishment risk

Foreign companies conducting business activities in Kazakhstan without a registered entity may create a permanent establishment (PE) — triggering CIT liability on profits attributable to the PE. Bond Stone advises on PE risk assessment for foreign companies operating in Kazakhstan through service agreements, representative offices, and seconded employees — and on structuring activities to manage PE exposure.

BEPS — multilateral instrument

Kazakhstan has signed the OECD Multilateral Instrument (MLI) — which modifies certain provisions of Kazakhstan’s existing DTTs to implement BEPS minimum standards, including the principal purpose test (PPT) and hybrid mismatch rules. Bond Stone advises on the impact of the MLI on Kazakhstan-related holding and financing structures.

DTT Planning — Chinese Manufacturing

Tax Advisory · Kazakhstan · China

Advising a Chinese manufacturer on applying the China-Kazakhstan DTT to reduce dividend withholding tax — beneficial ownership analysis, 5% reduced rate eligibility, documentation requirements, and coordination with Chinese tax advisers on the PRC side of the structure.

AIFC Tax Residency — Fintech Investor

Tax Advisory · AIFC · Fintech

Advising an international fintech investor on AIFC investment tax residency — eligibility analysis, 0% CIT on qualifying income, 0% WHT on dividends, and structuring investment activity through an AIFC participant entity to access the AIFC tax regime.

Transfer Pricing — Intercompany Loans

Tax Advisory · Kazakhstan · Corporate

Advising on structuring intercompany loan arrangements between a Kazakhstani subsidiary and its foreign parent — thin capitalisation analysis, arm’s length interest rate determination, WHT on interest, and transfer pricing documentation for Kazakhstani tax authority review.

IPP Tax Incentive — Manufacturing

Tax Advisory · Kazakhstan · Manufacturing

Advising a foreign manufacturer on Investment Priority Project tax incentives — CIT exemption scope, qualifying income structuring, VAT refund on construction costs, land and property tax exemption management, and tax stability guarantee in the investment contract.

PE Risk Assessment — Service Agreement

Tax Advisory · Kazakhstan · Energy

Advising a foreign energy services company on PE risk arising from its service activities in Kazakhstan — activity threshold analysis under the applicable DTT, structuring recommendations to manage PE exposure, and coordination with Kazakhstani tax counsel on registration obligations.

M&A Tax Structuring — AIFC Holding

Tax Advisory · AIFC · M&A

Advising on the tax structuring of an M&A transaction through an AIFC holding company — AIFC tax residency for the holding entity, 0% WHT on dividends from the Kazakhstani operating subsidiary to the AIFC holder, and overall effective tax rate analysis for the investment structure.