Standard CIT rate — 20%

The standard corporate income tax rate in Kazakhstan is 20% under the Tax Code No. 214-VIII effective 1 January 2026. Sector-specific rates apply: 25% for banks and gambling businesses (20% for bank income from business lending); 5% (2026) → 10% (2027) for social sector organisations; 3% for agricultural producers. CIT is levied on the taxable income of Kazakhstani legal entities and foreign legal entities operating through a permanent establishment in Kazakhstan. Taxable income is calculated as gross income less deductible expenses as defined by the Tax Code. Bond Stone advises on CIT position analysis as part of every investment structuring mandate.

Reduced CIT rates

The Tax Code provides reduced CIT rates for qualifying activities and sectors. Agricultural producers are subject to a reduced CIT rate of 3% under the new Tax Code. Banks and gambling businesses are subject to a 25% CIT rate (20% for bank income from business lending). Social sector organisations are subject to 5% CIT in 2026, increasing to 10% from 2027. Banks and insurance organisations are subject to the standard 20% rate on most income. The specific reduced rates applicable under the new Tax Code No. 214-VIII should be verified at adilet.zan.kz — the new Tax Code introduced restructured rate provisions that may differ from the previous Tax Code No. 120-VI framework.

Investment Priority Project — 0% CIT exemption

Investors holding Investment Priority Project (IPP) status under the Entrepreneurial Code No. 375-V are entitled to a CIT reduction to 0% on qualifying income for up to 10 years from commencement of commercial production. The CIT exemption applies only to income derived from the qualifying investment activity specified in the investment contract. Income from other activities of the same entity is taxed at the standard 20% rate. Bond Stone advises on structuring the investment entity to maximise qualifying income under the IPP CIT exemption.

AIFC participant — 0% CIT

Legal entities that are participants of the Astana International Financial Centre (AIFC) and conduct qualifying financial services activities within the AIFC are entitled to 0% CIT on qualifying income under the AIFC tax regime. This is one of the most significant tax benefits available to investors structuring through the AIFC — and makes the AIFC a compelling holding jurisdiction for investment income generated in Kazakhstan. Bond Stone’s AIFC RLA status enables it to advise on AIFC participant tax eligibility as part of the overall investment structuring mandate.

CIT deductible expenses — key items

Deductible expenses for CIT purposes include: business expenses incurred in the production of taxable income; depreciation on fixed assets (rates set by the Tax Code); interest on borrowings (subject to thin capitalisation limits on related-party debt); salaries and social contributions; and professional fees. Non-deductible items include: dividends paid to shareholders; penalties and fines; and expenses not supported by proper documentation. Bond Stone advises on the deductibility of specific expense categories in the context of investment structuring mandates.

New Tax Code 2026 — transitional provisions

The new Tax Code No. 214-VIII entered into force on 1 January 2026 — replacing Tax Code No. 120-VI dated 25 December 2017. Investors holding investment contracts concluded under the previous Tax Code framework are protected by the tax stability guarantee — they may elect to continue applying the tax conditions in force at the time their investment contract was concluded. Bond Stone advises on the application of transitional provisions and tax stability guarantees for existing investment contract holders under the new Tax Code framework.

CIT Structuring — Manufacturing IPP

CIT · Kazakhstan · Manufacturing

Advising a foreign manufacturer on CIT structuring under an Investment Priority Project investment contract — qualifying income scope, 0% CIT exemption period, separate accounting for exempt and non-exempt income, and interaction with the new Tax Code No. 214-VIII.

AIFC 0% CIT — Fintech Holding

CIT · AIFC · Fintech

Advising an international fintech investor on structuring through an AIFC participant entity to access the 0% CIT regime — qualifying activity analysis, AIFC participant registration, and overall effective tax rate for the investment structure.

CIT Deductibility — Intercompany Services

CIT · Kazakhstan · Corporate

Advising on the CIT deductibility of management fee payments from a Kazakhstani subsidiary to its foreign parent — arm’s length analysis, documentation requirements, and thin capitalisation impact on related-party interest deductibility.

Tax Code 2026 — Impact Assessment

CIT · Kazakhstan · Corporate

Advising an existing investor on the impact of Tax Code No. 214-VIII on its Kazakhstani CIT position — comparing new and old Tax Code provisions, transitional arrangement eligibility, and tax stability guarantee application.

CIT PE — Foreign Service Company

CIT · Kazakhstan · Energy

Advising a foreign energy services company on CIT liability arising from a permanent establishment in Kazakhstan — PE profit attribution methodology, deductible expenses allocated to the PE, and CIT filing obligations.

CIT + DTT — Holding Structure

CIT · Kazakhstan · M&A

Advising on CIT and DTT planning for an M&A transaction — structuring the acquisition through a treaty-protected holding entity to reduce Kazakhstani CIT on disposal gains and WHT on dividends flowing up to the acquirer.