FOREIGN INVESTMENT \u00b7 KAZAKHSTAN<\/p>\n
Bond Stone advises investors on the tax preference regime applicable to Investment Priority Projects in Kazakhstan \u2014 corporate income tax (CIT) reduction, land tax exemption, property tax exemption, and VAT refund on construction costs under the Entrepreneurial Code (Article 290) and the Tax Code (previously Articles 712\u2013717 of Tax Code No. 120-VI \u2014 verify current numbering under Tax Code No. 214-VIII).<\/p>\n
Primary authority: Tax Code of the Republic of Kazakhstan No. 214-VIII dated 18 July 2025 (entered into force 1 January 2026), replacing Tax Code No. 120-VI dated 25 December 2017; Entrepreneurial Code of the Republic of Kazakhstan No. 375-V dated 29 October 2015, Article 290 (tax preferences procedure). Note: article numbers below reflect the previous Tax Code No. 120-VI \u2014 verify current article numbering under Tax Code No. 214-VIII at adilet.zan.kz. Authority: adilet.zan.kz Authority: adilet.zan.kz<\/a><\/p>\n CIT reduction \u2014 Tax Code Article 712<\/p>\n Investment Priority Project holders are entitled to a CIT reduction under Tax Code Article 712 \u2014 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.<\/p>\n<\/p><\/div>\n Land tax exemption \u2014 Tax Code Article 714<\/p>\n 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.<\/p>\n<\/p><\/div>\n Property tax exemption \u2014 Tax Code Article 715<\/p>\n 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.<\/p>\n<\/p><\/div>\n VAT refund on construction \u2014 Tax Code Article 717<\/p>\n 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.<\/p>\n<\/p><\/div>\n Tax stability guarantee<\/p>\n 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.<\/p>\n<\/p><\/div>\n Interaction with double taxation treaties<\/p>\n 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.<\/p>\n<\/p><\/div>\n<\/div>\n Bond Stone has advised foreign investors on investment incentive structuring in Kazakhstan since 2007. Client confidentiality is maintained across all matters.<\/p>\n CIT Reduction \u2014 Manufacturing IPP<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Manufacturing<\/p>\n Advising a foreign manufacturer on applying Tax Code Article 712 CIT reduction under an IPP investment contract \u2014 scope of qualifying income, 10-year exemption period, and structuring income streams to maximise the zero-rate benefit.<\/p>\n<\/p><\/div>\n VAT Refund \u2014 Construction Phase<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Construction<\/p>\n Advising an IPP holder on VAT refund claims under Tax Code Article 717 for construction and installation works \u2014 documentation requirements, refund application procedure, and timeline for VAT recovery.<\/p>\n<\/p><\/div>\n Property Tax Exemption \u2014 Asset Classification<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Tax<\/p>\n Advising on asset classification for IPP property tax exemption under Tax Code Article 715 \u2014 identifying qualifying fixed assets, placement-in-service date, and 8-year exemption period management.<\/p>\n<\/p><\/div>\n Tax Stability Guarantee \u2014 Contract Negotiation<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Advisory<\/p>\n Advising an investor on negotiating the tax stability guarantee in an IPP investment contract \u2014 scope of protected conditions, adverse change trigger definition, and election mechanism for continuing pre-contract tax rates.<\/p>\n<\/p><\/div>\n DTT + IPP \u2014 Combined Optimisation<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Tax<\/p>\n Advising on combining IPP tax preferences with Kazakhstan double taxation treaty benefits \u2014 CIT reduction on operating income, DTT-reduced withholding tax on dividend repatriation, and overall effective tax rate analysis.<\/p>\n<\/p><\/div>\n Tax Compliance \u2014 IPP Contract Period<\/p>\n Tax Preferences \u00b7 Kazakhstan \u00b7 Compliance<\/p>\n Advising an IPP holder on tax compliance obligations throughout the investment contract period \u2014 qualifying activity monitoring, separate accounting for exempt and non-exempt income, annual preference reporting, and audit risk assessment.<\/p>\n<\/p><\/div>\n<\/div>\n Why Bond Stone<\/p>\n \u2726 18+ years advising foreign investors on investment incentive structures in Kazakhstan<\/p>\n \u2726 Active investment contract mandates \u2014 IPP, SIP, SEZ, and customs exemption advisory<\/p>\n \u2726 Committee on Investments relationships \u2014 coordinating investment contract applications<\/p>\n \u2726 Ranked Legal 500 EMEA and IFLR1000 \u2014 Almaty and Astana offices<\/p>\n<\/div>\n Primary authority: adilet.zan.kz<\/a><\/p>\n Contact Bond Stone for a confidential discussion about Tax Preferences Under Investment Priority Project in Kazakhstan.<\/p>\n \n\ud83d\udce7 info@bondstonelaw.com<\/a> \nRequest a Confidential Consultation<\/a> FOREIGN INVESTMENT \u00b7 KAZAKHSTAN Tax Preferences Under Investment Priority Project in Kazakhstan Bond Stone advises investors on the tax preference regime applicable to Investment Priority Projects in Kazakhstan \u2014 corporate income tax (CIT) reduction, land tax exemption, property tax exemption, and VAT refund on construction costs under the Entrepreneurial Code (Article 290) and the Tax […]<\/p>\n","protected":false},"author":4,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-3916","page","type-page","status-publish","hentry"],"translation":{"provider":"WPGlobus","version":"3.0.3","language":"ru","enabled_languages":["en","ru"],"languages":{"en":{"title":true,"content":true,"excerpt":false},"ru":{"title":false,"content":false,"excerpt":false}}},"_links":{"self":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/3916","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/users\/4"}],"replies":[{"embeddable":true,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/comments?post=3916"}],"version-history":[{"count":2,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/3916\/revisions"}],"predecessor-version":[{"id":4769,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/3916\/revisions\/4769"}],"wp:attachment":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/media?parent=3916"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\nLegal Framework<\/h2>\n
\nExperience<\/h2>\n
\nDiscuss your Kazakhstan investment incentives<\/h2>\n
\n\ud83d\udcde +7 (701) 729 76 72<\/a>\n<\/p>\n
\n\u2190 Special Investment Project<\/a>
\nState In-kind Grants \u2192<\/a>
\n\u2190 Foreign Investment Hub<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"