Tax in Kazakhstan

Who is the tax authority and where do filings live?

Kazakhstan's State Revenue Committee (Komitet gosudarstvennykh dokhodov, KGD), under the Ministry of Finance, is Kazakhstan's tax and customs authority [SC1]. KGD operates regional administrations and the Department for the Largest Taxpayers. Filings flow through the eGov.kz portal and the KGD electronic services. Tax disputes proceed through KGD internal review, the Tax Appellate Commission, and the administrative courts. The credentialed Kazakh tax-and-accounting professions are CAP (Certified Accountant of Kazakhstan) regulated by the Chamber of Auditors of the Republic of Kazakhstan. Substantive law: Tax Code of the Republic of Kazakhstan (Nalogovyi kodeks Respubliki Kazakhstan, codified single statute since 1 January 2018 under Law 120-VI; the 2024 New Tax Code draft is under Mazhilis consideration with target effective date 1 January 2026), and successive amendment laws. Kazakhstan is a member of the Eurasian Economic Union (EAEU) Customs Union (with Russia, Belarus, Armenia, Kyrgyzstan), creating a regional trade-and-tax-coordination framework. The Astana International Financial Centre (AIFC) operates as a special legal regime under English-law-based regulatory framework for international financial-services activities.

What is the tax year and when are returns due?

The individual tax year is the calendar year. Personal income tax returns (Form 240.00) are due 31 March of the year following the tax year for individuals required to file (those with foreign-source income, individual entrepreneurs, certain professional categories) [SC1]. Wage earners' income tax (IPN) is fully withheld monthly by employers under Article 351 of the Tax Code. Corporate fiscal years align with the calendar year (with limited exception); annual corporate income tax returns (Form 100.00) are due 31 March of the year following fiscal year-end. Quarterly advance corporate tax instalments apply for taxpayers above specified annual revenue thresholds. VAT returns are filed quarterly under the standard regime by the 15th of the second month following the quarter; monthly is available for specified large taxpayers. The Universal Income Declaration framework has been progressively rolled out since 2021 for state employees with phased expansion to broader population categories. Annual financial statements are required for in-scope corporations.

Who is a Kazakh tax resident?

Under Article 217 of the Tax Code, an individual is tax resident in Kazakhstan if (a) being physically present in Kazakhstan for at least 183 days (continuously or with interruptions) in any 12-month period that ends in the relevant tax year, OR (b) maintaining their centre of vital interests in Kazakhstan (with permanent residence registration as primary indicator), OR (c) being a Kazakh citizen working abroad as a Kazakh state employee [SC2]. Residents are taxed on worldwide income; non-residents on Kazakh-source income at flat or schedular rates (typically 20 percent on most categories with treaty rates applying). Treaty tie-breakers under the OECD Model framework apply for dual-residents. PE attribution under Kazakhstan treaty network and domestic Tax Code follows OECD Model definitions. Tax Residency Certificate procedure under KGD provides foreign-residency-certificate counterparts. Foreign nationals working in Kazakhstan on long-term assignments routinely meet the 183-day test from year one of assignment.

What are the personal income tax rates?

Kazakhstan applies a flat 10 percent personal income tax (Individualnyi podokhodnyi nalog, IPN) on most income categories: employment, self-employment, capital gains, rental [SC1]. Investment income (dividends from Kazakh companies received from listed-share holdings on the Astana International Exchange) is generally exempt at the shareholder level under specific conditions; dividends from non-listed Kazakh companies face 5 percent flat at distribution. Interest income from Kazakh financial institutions to individuals faces 10 percent withholding (final). Capital gains face 10 percent flat for individual non-business holdings. The 2024 New Tax Code reform proposes progressive rates (5/10/15/20 percent across income bands) for personal income tax effective from 2026; under the current 2024 framework, the flat 10 percent remains. Mandatory pension contributions add 10 percent (employee-side); social tax 9.5 percent and social health insurance 3 percent (employer-side). Specific deductions include qualifying medical expenses and mortgage interest under the Mortgage Tax Deduction framework.

How does Kazakhstan's corporate tax work?

The corporate income tax (Korporativnyi podokhodnyi nalog, KPN) rate is 20 percent on taxable profit for resident companies [SC2]. Specific industry rates: companies engaged in production of agricultural products at 6 percent KPN (under the simplified regime if conditions met); SMEs may elect the simplified declaration regime (3 percent on revenue) with quarterly filings. Subsoil-use sectors (oil/gas/mining) face elevated KPN of 20 percent plus excess profit tax under specific schedules. Withholding tax on dividends to non-residents is 15 percent (treaty rates apply; 0 percent for qualifying participation under specific conditions); royalties 15 percent default; technical-services 20 percent default; interest 15 percent default. Pillar Two: Kazakhstan is not yet a formal QDMTT/IIR transposer but has signaled progressive alignment with OECD GloBE rules; the 2024 New Tax Code draft includes Pillar Two provisions targeting effective from 2026. Tax loss carryforwards: 10 years; carryback unavailable. AIFC entities benefit from special tax-incentive regime including 0 percent CIT for qualifying activities through 31 December 2065 under specific Constitutional-Statute provisions. Transfer pricing under Section 11 of the Tax Code follows OECD principles with master-file + local-file + CbCR for in-scope groups.

What about NDS (VAT)?

The standard VAT rate (Nalog na dobavlennuyu stoimost', NDS) is 12 percent under the Tax Code — one of the lowest standard rates in the OECD [SC3]. Zero-rated supplies include exports of goods and services. Exempt supplies include healthcare, education, financial services (under specific definitions), residential rental, and several other social-policy categories. Registration threshold is 30,000 monthly calculation indices (MCI) of annual turnover (~KZT 110.7m for 2024). Reverse-charge mechanism applies on imported services. Foreign-supplier registration for B2C cross-border digital services applies under the 'Google Tax' provisions effective from 1 January 2022 — non-resident digital service providers register and remit VAT on B2C streaming, marketplace, and SaaS supplies. The 2024 New Tax Code draft proposes raising the standard rate to 16 percent effective from 2026 (subject to legislative passage). Excise Tax applies on alcohol, tobacco, fuels, and specified other goods. Customs-VAT on imports collected at the border by KGD Customs.

How are cryptoassets taxed?

Kazakhstan adopted the Law 'On Digital Assets in the Republic of Kazakhstan' (Law 193-VII, effective 1 April 2023), establishing the regulatory framework for digital assets and dedicated tax treatment under the Tax Code [SC2]. Capital gains on individual cryptoasset disposals are taxed under the personal income tax framework at 10 percent flat on net gain, with acquisition cost deductible (FIFO method assumed). Mining operations are subject to a dedicated digital-mining license fee plus standard corporate income tax. The Astana International Financial Centre (AIFC) provides a special regulatory regime for licensed crypto-asset service providers under Astana Financial Services Authority (AFSA) supervision, with concessional tax treatment for AIFC-resident CASP entities. Crypto-asset service providers outside AIFC operate under the National Bank of Kazakhstan (NBK) and AFSA framework. Receipt of crypto as employment compensation is taxable under standard PIT framework with KZT-equivalent value at receipt. NFTs and stablecoins fall under the Law 193-VII framework with case-by-case classification. Kazakhstan has been a regional first-mover on dedicated cryptoasset legislation in Central Asia.

What is the treaty network and what are the audit triggers?

Kazakhstan has approximately 55 active double tax treaties [SC4]. The treaty network covers Russia, China, India, USA, UK, Germany, France, Netherlands, Italy, Spain, Switzerland, Sweden, Korea, Japan, Singapore, UAE, Turkey, Iran, Pakistan, Czech Republic, Poland, Hungary, Belarus, Armenia, Kyrgyzstan, Uzbekistan, Azerbaijan, Georgia, Ukraine, Estonia, Latvia, Lithuania, Mongolia, Vietnam, Malaysia, and several other counterparties. Kazakhstan ratified the OECD MLI on 24 June 2020 with modifications entering force from 1 October 2020 onward depending on counterparty. Audit triggers include: disproportionate VAT credits relative to declared output; transfer-pricing non-compliance under Section 11 of the Tax Code (Articles 175-189, TPD/CbCR documentation thresholds aligned with OECD principles); undeclared bank deposits flagged via expanding CRS exchanges (Kazakhstan adopted CRS framework under the Multilateral Competent Authority Agreement effective from 2020); and the Universal Income Declaration (Vseobshchee deklarirovanie) regime that has been progressively rolled out since 2021. Standard SOL is 5 years from the tax year; extended for fraud or non-filing.

What are the common penalties and pitfalls for foreigners?

The Kazakh penalty framework under the Tax Code imposes administrative-fine sanctions for late filings (escalating fixed penalty plus default interest), failure to file (escalating penalty plus assessment-by-KGD-estimate exposure), incorrect declarations (15-50 percent of underreported tax depending on intent), and failure to maintain accounting records (escalating administrative fine plus assessment-by-KGD-estimate exposure) [SC5]. Default interest accrues at the prevailing NBK refinancing rate plus statutory margin on unpaid tax. Tax-evasion criminal exposure under the Criminal Code carries fines and imprisonment for grossly-significant evasion. Common foreign-national pitfalls: (1) the centre-of-vital-interests test under Article 217(b) considers permanent residence registration as primary indicator — foreign nationals with Kazakh registration face residency exposure even with limited physical presence; (2) the Universal Income Declaration framework progressively expanded since 2021 creates broad disclosure obligations; (3) the AIFC concessional regime has specific compliance requirements — losing register-compliance status triggers ordinary CIT; (4) Pillar Two transposition pending under 2024 New Tax Code targeting 2026 effective; (5) the EAEU Customs Union framework creates regional indirect-tax coordination affecting cross-border supply flows; (6) the post-2018 Tax Code under Law 120-VI consolidated framework requires careful section-mapping for practitioners familiar with prior framework; (7) cross-border digital-services VAT under Google Tax effective 1 January 2022 has been progressively enforced; (8) Law 193-VII on Digital Assets effective 1 April 2023 created dedicated cryptoasset framework requiring careful classification analysis; (9) subsoil-use elevated KPN plus excess profit tax framework creates substantial sector-specific burden; and (10) the 2024 New Tax Code draft proposes substantial rate increases (VAT to 16 percent, progressive PIT to 20 percent top) effective from 2026 — practitioners should track legislative progress.