CIT reduction — Tax Code Article 712

Investment Priority Project holders are entitled to a CIT reduction under Tax Code Article 712 — reducing the applicable CIT rate by 100% (effectively a zero rate) for a period of up to 10 years from the commencement of commercial production. The CIT reduction 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 CIT rate (20% under the Tax Code). Bond Stone advises on structuring the investment entity to maximise the scope of income qualifying for the CIT reduction.

Land tax exemption — Tax Code Article 714

Investment Priority Project holders are entitled to land tax exemption under Tax Code Article 714 for up to 10 years from the date of conclusion of the investment contract. The exemption applies to land plots used for the qualifying investment activity. Bond Stone advises on the documentation required to claim and maintain the land tax exemption and on the consequences of non-compliance with investment contract conditions.

Property tax exemption — Tax Code Article 715

Investment Priority Project holders are entitled to property tax exemption under Tax Code Article 715 for up to 8 years from the date the investment property is placed in service. The exemption applies to fixed assets acquired for the qualifying investment activity. Bond Stone advises on the scope of the property tax exemption and on the asset classification requirements for qualifying property.

VAT refund on construction — Tax Code Article 717

Investment Priority Project holders are entitled to a refund of VAT paid on construction and installation works related to the qualifying investment project under Tax Code Article 717. The VAT refund is available on the costs of constructing new production facilities or expanding existing ones under the investment contract. Bond Stone advises on the VAT refund application procedure and the documentation required to substantiate the refund claim.

Tax stability guarantee

The investment contract for an Investment Priority Project includes a stability guarantee that protects the tax conditions applicable to the project against adverse legislative changes for the duration of the contract. If the Tax Code is amended in a manner that worsens the investor’s tax position during the contract period, the investor may elect to continue applying the tax conditions in force at the time the investment contract was concluded. Bond Stone advises on the scope and limitations of the tax stability guarantee in investment contract negotiations.

Interaction with double taxation treaties

Tax preferences under an IPP investment contract operate alongside Kazakhstan’s double taxation treaty network. Where a DTT reduces withholding tax on dividends or interest paid to foreign investors, the DTT benefit applies in addition to the IPP tax preferences. Bond Stone advises on optimising the combined effect of IPP tax preferences and applicable DTT benefits in the overall investment tax structure.

CIT Reduction — Manufacturing IPP

Tax Preferences · Kazakhstan · Manufacturing

Advising a foreign manufacturer on applying Tax Code Article 712 CIT reduction under an IPP investment contract — scope of qualifying income, 10-year exemption period, and structuring income streams to maximise the zero-rate benefit.

VAT Refund — Construction Phase

Tax Preferences · Kazakhstan · Construction

Advising an IPP holder on VAT refund claims under Tax Code Article 717 for construction and installation works — documentation requirements, refund application procedure, and timeline for VAT recovery.

Property Tax Exemption — Asset Classification

Tax Preferences · Kazakhstan · Tax

Advising on asset classification for IPP property tax exemption under Tax Code Article 715 — identifying qualifying fixed assets, placement-in-service date, and 8-year exemption period management.

Tax Stability Guarantee — Contract Negotiation

Tax Preferences · Kazakhstan · Advisory

Advising an investor on negotiating the tax stability guarantee in an IPP investment contract — scope of protected conditions, adverse change trigger definition, and election mechanism for continuing pre-contract tax rates.

DTT + IPP — Combined Optimisation

Tax Preferences · Kazakhstan · Tax

Advising on combining IPP tax preferences with Kazakhstan double taxation treaty benefits — CIT reduction on operating income, DTT-reduced withholding tax on dividend repatriation, and overall effective tax rate analysis.

Tax Compliance — IPP Contract Period

Tax Preferences · Kazakhstan · Compliance

Advising an IPP holder on tax compliance obligations throughout the investment contract period — qualifying activity monitoring, separate accounting for exempt and non-exempt income, annual preference reporting, and audit risk assessment.