TAX ADVISORY \u00b7 KAZAKHSTAN<\/p>\n
Bond Stone advises international investors and multinational corporations on corporate income tax (CIT) in Kazakhstan \u2014 standard rate, reduced rates for qualifying sectors, investment incentive CIT exemptions under Investment Priority Projects, AIFC participant 0% CIT, and the impact of the new Tax Code No. 214-VIII effective 1 January 2026.<\/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). Verify current provisions at adilet.zan.kz<\/a><\/p>\n Standard CIT rate \u2014 20%<\/p>\n 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) \u2192 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.<\/p>\n<\/p><\/div>\n Reduced CIT rates<\/p>\n 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 \u2014 the new Tax Code introduced restructured rate provisions that may differ from the previous Tax Code No. 120-VI framework.<\/p>\n<\/p><\/div>\n Investment Priority Project \u2014 0% CIT exemption<\/p>\n 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.<\/p>\n<\/p><\/div>\n AIFC participant \u2014 0% CIT<\/p>\n 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 \u2014 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.<\/p>\n<\/p><\/div>\n CIT deductible expenses \u2014 key items<\/p>\n 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.<\/p>\n<\/p><\/div>\n New Tax Code 2026 \u2014 transitional provisions<\/p>\n The new Tax Code No. 214-VIII entered into force on 1 January 2026 \u2014 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 \u2014 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.<\/p>\n<\/p><\/div>\n<\/div>\n Bond Stone has provided tax advisory as part of investment structuring and M&A mandates in Kazakhstan since 2007. Client confidentiality is maintained across all matters.<\/p>\n CIT Structuring \u2014 Manufacturing IPP<\/p>\n CIT \u00b7 Kazakhstan \u00b7 Manufacturing<\/p>\n Advising a foreign manufacturer on CIT structuring under an Investment Priority Project investment contract \u2014 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.<\/p>\n<\/p><\/div>\n AIFC 0% CIT \u2014 Fintech Holding<\/p>\n CIT \u00b7 AIFC \u00b7 Fintech<\/p>\n Advising an international fintech investor on structuring through an AIFC participant entity to access the 0% CIT regime \u2014 qualifying activity analysis, AIFC participant registration, and overall effective tax rate for the investment structure.<\/p>\n<\/p><\/div>\n CIT Deductibility \u2014 Intercompany Services<\/p>\n CIT \u00b7 Kazakhstan \u00b7 Corporate<\/p>\n Advising on the CIT deductibility of management fee payments from a Kazakhstani subsidiary to its foreign parent \u2014 arm’s length analysis, documentation requirements, and thin capitalisation impact on related-party interest deductibility.<\/p>\n<\/p><\/div>\n Tax Code 2026 \u2014 Impact Assessment<\/p>\n CIT \u00b7 Kazakhstan \u00b7 Corporate<\/p>\n Advising an existing investor on the impact of Tax Code No. 214-VIII on its Kazakhstani CIT position \u2014 comparing new and old Tax Code provisions, transitional arrangement eligibility, and tax stability guarantee application.<\/p>\n<\/p><\/div>\n CIT PE \u2014 Foreign Service Company<\/p>\n CIT \u00b7 Kazakhstan \u00b7 Energy<\/p>\n Advising a foreign energy services company on CIT liability arising from a permanent establishment in Kazakhstan \u2014 PE profit attribution methodology, deductible expenses allocated to the PE, and CIT filing obligations.<\/p>\n<\/p><\/div>\n CIT + DTT \u2014 Holding Structure<\/p>\n CIT \u00b7 Kazakhstan \u00b7 M&A<\/p>\n Advising on CIT and DTT planning for an M&A transaction \u2014 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.<\/p>\n<\/p><\/div>\n<\/div>\n Why Bond Stone<\/p>\n \u2726 Investment-perspective tax advisory \u2014 tax efficiency built into every investment and M&A mandate<\/p>\n \u2726 AIFC RLA status \u2014 AIFC tax regime and 0% WHT structuring on a single mandate<\/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 Corporate Income Tax in Kazakhstan.<\/p>\n \n\ud83d\udce7 info@bondstonelaw.com<\/a> \nRequest a Confidential Consultation<\/a> TAX ADVISORY \u00b7 KAZAKHSTAN Corporate Income Tax in Kazakhstan Bond Stone advises international investors and multinational corporations on corporate income tax (CIT) in Kazakhstan \u2014 standard rate, reduced rates for qualifying sectors, investment incentive CIT exemptions under Investment Priority Projects, AIFC participant 0% CIT, and the impact of the new Tax Code No. 214-VIII effective […]<\/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-4795","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\/4795","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=4795"}],"version-history":[{"count":2,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/4795\/revisions"}],"predecessor-version":[{"id":4797,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/4795\/revisions\/4797"}],"wp:attachment":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/media?parent=4795"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
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