KYRGYZSTAN · TAX

Tax in Kyrgyzstan for Foreign Investors

A Kyrgyz company under the general regime pays profit tax at 10%, charges VAT at 12% and also pays a sales tax of 1% to 3% on turnover. Dividends, interest, royalties and services paid to a foreign company without a permanent establishment are taxed at source at 10%, unless a tax treaty provides otherwise, and dividends received by Kyrgyz companies are exempt from profit tax until 1 January 2031. A business whose activity is not excluded may opt instead for a single tax on revenue, mostly at 0.5% to 6%, which replaces profit tax, sales tax and VAT. Activity of a free economic zone entity that meets the conditions is exempt from all taxes. As an EAEU member, Kyrgyzstan applies the common customs tariff, and VAT on goods imported from other EAEU states is paid to the tax authority rather than at the border.

This page summarises the Tax Code No. 3 of 18 January 2022 in its edition of 6 August 2026, which includes the amendments made by Law No. 145 of that date. Employment taxes and social contributions are covered on Employment and Work Permits in Kyrgyzstan; tax on the sale of shares is also discussed on Company Law and M&A in Kyrgyzstan.

Legal framework

Taxes are administered by the State Tax Service under the Cabinet of Ministers (Regulation approved by Cabinet Resolution No. 592 of 19 September 2025). The stabilisation regime under the investment law covers taxes including VAT, but not other indirect taxes (Tax Code, Art. 1(4)).

Headline rates

Permanent establishment

A foreign company is taxed in Kyrgyzstan on business profits if it has a permanent establishment there. This includes a place of management, branch, office, factory or workshop, a construction or assembly site lasting 183 days or more, services through personnel present for 183 days or more in any 12-month period, and business through a dependent agent who is authorised to act for the foreign company and earns more than 75% of its revenue from it. The list also covers the sale of goods in Kyrgyzstan and electronic services through a domain name or IP address registered in Kyrgyzstan (Art. 28(2)). A foreign company without a permanent establishment is taxed only by withholding on Kyrgyz-source income.

Profit tax

The tax period is the calendar year (Art. 211). Companies file a single tax return by 1 April of the following year (Art. 106) and pay the final tax by the filing deadline (Art. 242). Losses may be carried forward for up to five years (Art. 232). Dividends received from Kyrgyz and foreign companies are not taxable until 1 January 2031 (Art. 213(1)(7)).

The standard rate is 10% (Art. 240(1)). A 0% rate applies to mining and sale of ores and concentrates of gold, silver, copper, antimony, mercury, tungsten and tin and to their refined products (Art. 240(2)); that activity is taxed in other ways, including royalties, covered in Mining Licences in Kyrgyzstan. A Kyrgyz company making a qualifying large investment pays 0% on profit for five consecutive years starting after the year of first profit from the new equipment, but not on profit from mineral extraction, trade or excisable goods (Art. 240(4)).

Sales tax

Domestic companies, foreign companies with a permanent establishment and individual entrepreneurs pay sales tax on revenue (Art. 363). Under the general regime the rate is 1% for trade and manufacturing and 2% for other activity where the sales are subject to VAT, and 2% and 3% respectively where they are not. Banks pay 2%, insurers 2% and mobile operators and sellers of virtual assets 5% (Art. 368). The period is the calendar month (Art. 369). Foreign investors used to markets without a turnover tax often leave it out of their models.

VAT

VAT is charged at 12% on taxable supplies and imports (Art. 254(1)). A business under the general regime must register for VAT when it registers for tax, or from the month after it starts activity; there is no turnover threshold for general regime taxpayers (Art. 255). Exports of goods are zero-rated, except metal-bearing ores, concentrates, alloys and refined metals (Art. 303(1)). Exempt supplies include land, residential property and the sale of an enterprise as a whole between two VAT payers (Art. 265), as well as financial and insurance services (Arts. 270, 273).

Imports of fixed assets worth at least 5,000 calculation indicators, which is KGS 500,000, for the importer's own production are exempt from import VAT if they fall within listed tariff headings and the importer is a VAT payer or single tax payer (Art. 301).

Withholding tax on payments abroad

The payer withholds the tax whether the payment is made in Kyrgyzstan or abroad, and reports and pays it by the 20th of the month after payment (Arts. 248(5), 250). If the payer fails to withhold, the tax becomes its own liability (Art. 250(3)). Gains of foreign individuals on Kyrgyz shares are taxed at the same 10% with the same five-year exemption (Art. 197(4)). For companies with certain tax incentives or an investment agreement providing incentives, the five-year period starts only after the incentive ends (Art. 249(2)(6)).

Tax treaties

A ratified international treaty prevails over the Tax Code (Art. 3(1)), and income of a foreign company without a permanent establishment is taxed in line with the treaty with its state of residence (Art. 248(1)); the domestic rates apply where there is no treaty (Art. 248(2)). Kyrgyzstan has ratified treaties with, among others, Kazakhstan, Russia, Belarus, Uzbekistan, Tajikistan, Armenia, Turkey, Germany, Switzerland, Austria, Finland, Poland, Hungary, the Czech Republic, Slovakia, the Netherlands, the United Kingdom, India, Korea, Canada, the United Arab Emirates, Saudi Arabia, Qatar and Kuwait, and in June 2026 ratified a treaty with Japan. According to Japan's Ministry of Finance, the Japan treaty entered into force on 26 July 2026; on the Kyrgyz side it applies to withholding taxes on amounts paid on or after 1 January 2026 and to other taxes for taxable years beginning on or after 1 January 2027. The treaty with China is listed as in force in the official database. Check the treaty text and its entry into force for the specific payment; for comparison with Kazakhstan see Withholding Tax and DTT in Kazakhstan.

Transfer pricing

Price control is in Articles 139 and 140 of the Tax Code. The price agreed by the parties is presumed to be the market price. The tax authority may check prices in transactions between related parties (other than loans between them), barter, foreign trade transactions, transactions without supporting documents, and transactions with inactive or anonymous persons or with businesses on special regimes (Art. 139(2)). If the price differs from the market price by more than 20%, the authority may assess additional tax, interest and penalties as if market prices had applied (Art. 139(3)). The market price is set by regulated prices, exchange prices for metals and oil products, the National Statistical Committee's quarterly price bulletin, comparable transactions, the resale price method or the cost-plus method, applied in that order (Art. 140).

Special regimes

Single tax (simplified system)

The single tax replaces profit tax, sales tax and VAT on taxable supplies (Art. 418(1)). It is not available to foreign companies without a permanent establishment, banks, insurers, investment funds, securities market professionals, most excise taxpayers, miners of gold, silver, copper and the other listed metals, mobile and internet operators, or suppliers of heat, electricity and gas (Art. 419). A business that meets the criteria for splitting up a business loses the lowest rates (Art. 420(8)).

Other special regimes include tax based on a patent (Chapter 56) and the regime for residents of the High Technology Park (Chapter 59).

Free economic zones

Free economic zones are created by decision of the Cabinet of Ministers (FEZ Law, Art. 8). A company obtains zone status by signing an agreement on the conditions of activity with the zone's general directorate; the application states the planned activity, the land area and the planned capital investment, and attaches a business plan. The directorate decides within five working days (FEZ Law, Art. 11). Extraction of minerals is not permitted in a zone (Art. 5).

Activity of a zone entity that meets the conditions is exempt from all taxes (Tax Code, Art. 430(1)). The regime does not cover agency services, assembly, crypto mining or most excisable goods (Art. 427(1)). Goods produced in a zone and exported to other EAEU states are exempt from VAT and excise (Art. 430(5)). Goods moved from the zone into the rest of Kyrgyzstan bear VAT, services sold to the domestic market are taxed under the general regime, withholding tax still applies, and an entity working both inside and outside the zone must keep separate accounts (Art. 430(3), (6)–(8)). Social insurance contributions remain payable (FEZ Law, Art. 13(2)). Foreign goods brought into the zone are placed under the free customs zone procedure, without customs duties or taxes (FEZ Law, Art. 14).

EAEU customs and indirect taxes

Kyrgyzstan is part of the EAEU customs union, which applies the Common Customs Tariff to goods from third countries and allows goods to move between member states without customs declaration (EAEU Treaty, Arts. 25, 42). Indirect taxes in mutual trade follow the destination principle: exports are zero-rated and imports are taxed in the state of import (Art. 72).

• Imports from EAEU states. The importer files an indirect tax return with the tax authority and pays VAT by the 20th of the month after import, with the documents listed by the Cabinet of Ministers (Tax Code, Art. 320(1)–(2)). The taxable value is generally the contract price of the goods (Art. 311).
• Imports from third countries. VAT is paid in the order and terms of EAEU and Kyrgyz customs legislation (Art. 320(6)).
• Exports to EAEU states. The exporter must file the supporting documents with its VAT return within 180 days of shipment (Art. 303(2)).

Common mistakes foreign investors make

• Leaving sales tax out of the model. It is charged on turnover on top of profit tax and VAT.
• Assuming the five-year exemption on share gains during a tax holiday. For companies with certain incentives, the five years start only when the incentive ends.
• Treating free economic zone status as covering sales into Kyrgyzstan. Domestic sales and services are taxed under the general regime.
• Missing the 180-day documentation for EAEU exports, or paying import VAT on EAEU goods late.
• Choosing the single tax where it is excluded, for example in gold mining or mobile services, or where the business-splitting criteria apply.
• Setting related-party prices without support. A deviation of more than 20% from the market price allows the authority to reassess.
• Applying treaty rates without checking the treaty and whether it is in force for the year of payment.

Frequently Asked Questions

What is the corporate tax rate in Kyrgyzstan?

Profit tax is 10% (Tax Code, Art. 240(1)). Companies under the general regime also pay sales tax of 1% to 3% on turnover (Art. 368).

Is there withholding tax on dividends paid to a foreign parent?

Yes, 10% at source unless a tax treaty provides a lower rate (Arts. 248, 249).

Are dividends from a Kyrgyz subsidiary to a Kyrgyz holding company taxed?

No. Dividends received from Kyrgyz and foreign companies are not taxable income for profit tax purposes until 1 January 2031 (Art. 213(1)(7)).

Does a company in a free economic zone pay tax?

Activity that meets the conditions of the FEZ Law and Article 427 is exempt from all taxes (Art. 430(1)). Sales into the rest of Kyrgyzstan, domestic services and withholding on payments are taxed normally, and social insurance contributions are due.

Is VAT charged on goods bought from Kazakhstan?

Yes. Goods from EAEU states bear import VAT at 12%, declared and paid to the Kyrgyz tax authority by the 20th of the month after import (Art. 320).

Can a foreign-owned company use the single tax?

Yes, a Kyrgyz company with foreign owners may opt for it if its activity is not excluded by Article 419. A foreign company without a permanent establishment cannot.

Does Kyrgyzstan have transfer pricing rules?

The Tax Code allows the tax authority to test prices in related-party, barter and foreign trade transactions and to reassess where the price deviates by more than 20% from the market price (Arts. 139–140).

Bond Stone's Bishkek office advises foreign investors on the tax structure of Kyrgyz operations, free economic zone status and cross-border payments.

Related pages

Kyrgyzstan Legal Guide  ·  Business Formation in Kyrgyzstan  ·  Company Law and M&A in Kyrgyzstan  ·  Employment and Work Permits in Kyrgyzstan  ·  Mining Licences in Kyrgyzstan  ·  Withholding Tax and DTT in Kazakhstan  ·  Legal Services in Kyrgyzstan

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Primary sources: cbd.minjust.gov.kg — Tax Code No. 3 of 18 January 2022, edition of 6 August 2026 (Arts. 1, 3, 28, 106, 139, 140, 197, 211, 213, 232, 240, 242, 248–250, 254, 255, 265, 270, 273, 301, 303, 311, 320, 363, 368, 369, 418–420, 423, 427, 430); Law No. 6 on Free Economic Zones (Arts. 5, 8, 11, 13, 14); Regulation on the State Tax Service (Cabinet Resolution No. 592 of 19 September 2025); laws ratifying tax treaties; Treaty on the Eurasian Economic Union (Arts. 25, 42, 72), text at old.adilet.zan.kz.