Special Investment Project in Kazakhstan

What is a Special Investment Project?

A Special Investment Project (SIP) is an investment project carried out by a Kazakhstani legal entity under a special investment contract (Law on Industrial Policy, Articles 42-1 and 42-2). Three categories of investor qualify: (1) participants of a Special Economic Zone (SEZ); (2) owners of free warehouses under customs legislation; and (3) entities with an industrial assembly agreement for vehicles, agricultural machinery or their components. The regime left the Entrepreneurial Code on 1 January 2026, and the contract is now concluded with the authorised body for state stimulation of industry. For investment contracts concluded before that date, other than IPP and strategic project contracts, Article 839 of the Tax Code preserves the VAT exemption on imported raw materials until the contract expires.

SEZ participant — SIP incentives

SEZ participants with a special investment contract are exempt from customs duties on imported technological equipment, components and spare parts for 15 years, but not beyond the life of the SEZ (Law on Industrial Policy, Article 42-1). Raw materials and materials used are relieved of duty when the free customs zone procedure ends, if they can be identified in the finished product and their intended use is confirmed. VAT relief on import applies only on the conditions in the Tax Code (Articles 479 and 735). Land tax, property tax and CIT relief are not SIP incentives: they come from SEZ participation under Article 735 of the Tax Code. Bond Stone advises on combined SEZ + SIP incentive structures for manufacturing and processing investors.

Free warehouse owner — SIP incentives

Owners of free warehouses under customs legislation may conclude a special investment contract. The customs duty exemption runs for no more than 15 years from registration of the contract (Law on Industrial Policy, Article 42-1). Bond Stone advises on free warehouse status under the Customs Code No. 123-VI dated 26 December 2017 and the interaction between free warehouse status and SIP incentives.

Industrial assembly — SIP incentives

Entities with an industrial assembly agreement for vehicles, agricultural machinery or their components may conclude a special investment contract — providing a customs duty exemption for no more than 15 years from registration of the contract, and a VAT exemption on imported raw materials and materials on the conditions in Article 479 of the Tax Code.

SIP vs the investment agreement — key differences

New Investment Priority Project contracts are no longer available, so the comparison is now with the investment agreement under the Entrepreneurial Code. SIP status depends on the investor's position (SEZ participant, free warehouse owner, assembly agreement), not on a minimum investment; SIP incentives cover customs duties and import VAT, not CIT; and the customs relief can run for up to 15 years, against a maximum of 10 years for tax preferences under an investment agreement (Tax Code, Article 736(5)), within which property tax relief is limited to 8 years (Article 736(3)). SEZ participants cannot receive preferences under an investment agreement (Entrepreneurial Code, Article 283-1). Bond Stone advises on which route is most appropriate for a specific investment.