Special Economic Zones — framework

Kazakhstan’s SEZ framework is governed by the Entrepreneurial Code Articles 184–212. Kazakhstan currently operates 13 SEZs across various sectors and regions — including Astana (National Industrial Petrochemical Technology Park), Almaty (Khorgos Eastern Gates logistics), and sector-specific zones for manufacturing, agriculture, and IT. Each SEZ has specific qualifying activity requirements, minimum investment thresholds, and operating conditions. SEZ residents benefit from: 0% corporate income tax (CIT) on qualifying income; 0% VAT on goods produced within the SEZ; land tax and property tax exemptions; and customs duty relief on imported equipment and raw materials.

Investment priority projects

Investors qualifying as priority investors under the Entrepreneurial Code may obtain: CIT exemption for up to 10 years; land tax exemption for up to 10 years; property tax exemption for up to 8 years; and customs duty exemption on imported equipment. Priority investor status requires a minimum investment of 2 million MCI (approximately USD 17 million at current rates) and investment in a priority sector defined by government resolution. Bond Stone advises on priority investor qualification and the application process with the Ministry of Investment and Development.

Astana Hub — IT sector

The Astana Hub international technology park — established by Presidential Decree No. 636 dated 9 November 2018 — provides a simplified registration and tax incentive framework for IT companies. Residents of Astana Hub benefit from: income tax exemption until 2066; VAT exemption; exemption from social tax; and a simplified work permit regime for foreign IT specialists. Bond Stone advises on Astana Hub residency eligibility and registration.

Investment contracts — stability guarantees

Investors who qualify as priority investors may enter into investment contracts with the government of Kazakhstan under the Entrepreneurial Code — providing a stability guarantee that protects agreed tax and regulatory conditions against adverse legislative change for the duration of the contract (up to 25 years). Bond Stone advises on qualifying for and negotiating investment contracts with the relevant Kazakhstani state authority.

Tax treaties — double taxation relief

Kazakhstan has concluded double taxation treaties (DTTs) with 50+ states — including China, Germany, the Netherlands, UAE, UK, and USA. DTTs reduce or eliminate withholding tax on dividends, interest, and royalties paid to foreign investors. The applicable withholding tax rate on dividends under Kazakhstani domestic law is 15% — reduced by DTT to as low as 5% for qualifying corporate shareholders. Bond Stone advises on DTT eligibility analysis as part of every investment structuring mandate.

SEZ Application — Chinese Manufacturer

Incentives · Kazakhstan · SEZ · China

Advising a Chinese manufacturer on SEZ residency in Kazakhstan — eligibility assessment against qualifying activity requirements, minimum investment threshold analysis, application preparation, and review of SEZ operating conditions and tax incentive schedule.

Priority Investor Status — Energy Sector

Incentives · Kazakhstan · Energy

Advising a foreign energy investor on qualifying for priority investor status — investment threshold analysis, priority sector confirmation, application with the Ministry, and negotiation of investment contract with stability guarantee.

Astana Hub Registration — IT Company

Incentives · Kazakhstan · Technology

Advising a foreign IT company on registration as an Astana Hub resident — eligibility assessment, application preparation, income tax and VAT exemption confirmation, and work permit advisory for foreign IT specialists.

DTT Analysis — Dividend Repatriation

Incentives · Kazakhstan · Tax

Advising a foreign investor on applicable double taxation treaty rates for dividend repatriation from Kazakhstan — beneficial ownership analysis, treaty eligibility confirmation, and withholding tax optimisation.

SEZ Compliance — Operating Conditions

Incentives · Kazakhstan · SEZ

Advising a manufacturing company on compliance with SEZ operating conditions — qualifying activity monitoring, minimum investment fulfilment, annual compliance reporting, and assessment of risk of SEZ status revocation.

Investment Contract — Stability Guarantee

Incentives · Kazakhstan · Corporate

Advising a European investor on qualifying for and negotiating an investment contract with the government of Kazakhstan — priority investor eligibility, investment threshold confirmation, and stability guarantee scope negotiation.