Corporate Income Tax (CIT)

1. What CIT rates are provided for in the new Tax Code?

Answer:

The standard CIT rate remains at 20%.

For the banking sector, the CIT rate will be 25%, except for activities related to lending to business entities, which will continue to be taxed at 20%. The procedure for determining taxable income from banking activities carried out by second-tier banks will be established by the National Bank in coordination with the authorized body responsible for tax policy and the competent authority.

A higher CIT rate of 25% is also introduced for the activities of slot machine halls, totalizators, and bookmakers, while maintaining the existing gambling tax regime.

For the social sector (education and healthcare), a gradual increase in the CIT rate is proposed:

• 5% from 2026
• 10% from 2027

For agricultural producers, the CIT rate remains at 3%.

For agricultural cooperatives, the CIT rate is 6%.

2. The new Tax Code does not contain a provision similar to Article 239 of the current Tax Code regarding income from the operation of social facilities. How will such income be taxed from 2026?

Answer:

The new Tax Code does not contain separate provisions or require separate tax accounting for income derived from the operation of social facilities. Therefore, the general taxation procedure applies.

Accordingly, if income is generated from the operation of social facilities (even if insignificant), all expenses incurred to generate such income may be deducted for tax purposes.

3. Has the taxation procedure for non-profit organizations been retained? Can such organizations exempt their income from taxation?

Answer:

The new Tax Code provides two taxation options for non-profit organizations (NPOs) that allow exemption from taxation.

Option 1

If an NPO satisfies the two conditions established by the Law on Non-Profit Organizations (it does not distribute net income and does not have profit-making as its objective), the NPO may exclude certain types of income from its gross annual income for CIT purposes. Such income includes:

• Membership fees and contributions;
• Deposits and contributions to the organization;
• Income from government social contracts;
• Interest income on bank deposits;
• Foreign exchange gains;
• Property received free of charge;
• Contributions received by associations of property owners (OSI) and housing cooperatives (KSK).

Option 2

If an NPO qualifies as an organization engaged in social-sector activities, it may reduce its calculated CIT liability by 100%.

4. How does the new Tax Code encourage legal entities to employ persons with disabilities?

Answer:

Measures encouraging the employment of persons with disabilities already exist under the current Tax Code. The new Tax Code revises the conditions and approaches for applying tax incentives.

Corporate Income Tax (CIT)

1. Organizations of persons with disabilities may reduce CIT:
   • By 50% if they employ between 3 and 10 persons with disabilities;
   • By 100% if they employ more than 10 persons with disabilities.

To qualify for these incentives, the following additional requirements must be met:

• The average annual number of employees with disabilities must constitute at least 51% of total staff;
• Payroll expenses for employees with disabilities must account for at least 51% of total payroll expenses;
• At least 90% of the organization's income must be generated with the participation of employees with disabilities;
• Employees with disabilities must not simultaneously be employed by other organizations of persons with disabilities.

2. Taxpayers may reduce taxable income by:
   • An amount equal to double the payroll expenses of employees with disabilities; and
   • 50% of the social tax calculated on their salaries.
3. Taxpayers classified as social entrepreneurship entities may reduce taxable income by the amount of expenses incurred for vocational training, including where the employee is a person with a disability.

Value Added Tax (VAT)

Supplies of goods, works, and services are exempt from VAT if:

• During the tax period of the supply and the four preceding tax periods, both:
  • The average number of employees with disabilities is at least 51% of total employees; and
  • Payroll expenses for employees with disabilities represent at least 51% of total payroll expenses;
• At least 10 employees are persons with disabilities;
• The production of goods, provision of services, or performance of works involves employees with disabilities.

Social Tax

Specialized organizations of persons with disabilities, as defined by the Social Code, are exempt from social tax.

Vehicle Tax

Public associations of persons with disabilities are exempt from vehicle tax with respect to:

• One passenger vehicle with an engine capacity not exceeding 3,000 cubic centimeters; and
• One bus.

Land Tax

Specialized organizations of persons with disabilities apply a coefficient of 0 to land tax rates.

Property Tax

Specialized organizations of persons with disabilities calculate property tax at a rate of 0.1% of the tax base.

5. Can the 100% investment tax deduction for the acquisition of fixed assets be applied if the fixed assets are purchased on credit?

Answer:

Pursuant to Article 202(3) of the Tax Code, unless otherwise provided by Article 202(4), tax accounting is based on accounting records. The procedure for maintaining accounting documentation is governed by the legislation of the Republic of Kazakhstan on accounting and financial reporting.

According to Article 283(2) of the Tax Code, investment tax preferences may be applied at the taxpayer's discretion and consist of deducting costs included in the initial cost of a qualifying asset.

Article 283(3) establishes that qualifying assets include the following categories of assets under the fixed asset classification system:

• Buildings;
• Structures;
• Machinery;
• Equipment;
•  

Such assets must simultaneously satisfy the conditions specified in Article 283(3), including recognition as fixed assets, investment property, or intangible assets in accounting records, use in income-generating activities, and compliance with other statutory requirements.

Article 283(4) provides that the initial cost of a qualifying asset consists of costs incurred up to the date of recognition of the asset, including acquisition, production, construction, assembly, installation, and other costs that increase its value under IFRS or Kazakh accounting legislation.

In addition, IAS 16 “Property, Plant and Equipment” provides that the cost of an item of property, plant and equipment shall be recognized as an asset when:

• It is probable that future economic benefits associated with the item will flow to the entity; and
• The cost of the item can be measured reliably.

Therefore, investment tax preferences apply to assets recognized in accounting records as fixed assets in accordance with IFRS and/or Kazakhstan’s accounting legislation and which simultaneously satisfy the requirements established by Article 283(3).

It should be noted that the basis for applying the preference is the recognition of the asset as a fixed asset and the formation of its initial cost in accounting records, regardless of the financing method or settlement arrangements preceding such recognition. Accordingly, purchasing a fixed asset through credit financing does not in itself prevent the application of the investment tax preference.

6. If a taxpayer applies the 100% investment tax deduction upon acquisition or construction of a fixed asset, can depreciation deductions also be claimed?

Answer:

According to Article 274(1) of the Tax Code, deductions for fixed assets include depreciation calculated in accordance with Article 280.

However, pursuant to Article 275(2)(5), assets qualifying for investment tax preferences are not treated as fixed assets for tax purposes during the control period, provided the preferences have not been cancelled.

Accordingly, assets in respect of which investment tax preferences have been applied are not considered fixed assets during the control period and therefore are not eligible for depreciation deductions during that period.

7. If construction of a fixed asset began in 2025 but was completed and commissioned in 2026, can the 100% investment tax deduction be applied in 2026?

Answer:

According to Article 284(1) and (2) of the Tax Code, investment tax preferences may be applied using one of the following methods:

1. Deduction after recognition of the asset;
2. Deduction before recognition of the asset.

The method is selected in the taxpayer’s tax register for investment tax preferences for each qualifying asset.

Under the deduction-after-recognition method, the initial cost of the qualifying asset is deducted in the tax period in which the asset is recognized.

Pursuant to Article 283(5), the recognition date of a qualifying asset is, among other things, the date on which the asset is recognized in accounting records as a fixed asset, investment property, or intangible asset in accordance with IFRS and/or Kazakhstan’s accounting legislation.

Therefore, if the taxpayer chooses the deduction-after-recognition method, it is entitled to apply the investment tax preference in the form of a 100% deduction of the costs included in the initial cost of the asset in the tax period corresponding to the year in which the asset is recognized in accounting records as a fixed asset.

Accordingly, where construction commenced in 2025 but the asset was completed and recognized as a fixed asset in 2026, the taxpayer may apply the 100% investment tax deduction in 2026.

 

Value Added Tax (VAT)

8. What VAT rates are provided for in the new Tax Code?

Answer:

The standard VAT rate is 16%.

At the same time, differentiated VAT rates have been introduced.

The VAT exemption for peasant farms is retained.

For agricultural producer legal entities, it is proposed to increase the additional VAT credit from 70% to 80%. This measure is intended to eliminate grounds for increasing prices of agricultural products.

A reduced VAT rate is established for the supply of medicines, medical devices, and medical services:

• 5% from 2026
• 10% from 2027

In addition, VAT exemptions are proposed for:

• Medicines and medical services provided within the guaranteed volume of free medical care (GVFMC) and mandatory social health insurance (MSHI), as well as treatment of orphan and socially significant diseases included in a list approved by the Government;
• Domestically published books and printing services related to book publishing;
• Archaeological works.

9. How will the healthcare sector be subject to VAT from 2026?

Answer:

The new Tax Code provides the following VAT treatment for the healthcare sector:

1) VAT Exemptions

The following are exempt from VAT:

• The supply of medicines and medical services by healthcare entities licensed to conduct medical activities:
  • Within the framework of the Guaranteed Volume of Free Medical Care (GVFMC) and Mandatory Social Health Insurance (MSHI);
  • For the treatment of orphan and socially significant diseases.

The relevant list will be developed by the Ministry of Health of the Republic of Kazakhstan.

• The importation of medicines within the framework of GVFMC and MSHI, as well as for the treatment of orphan and socially significant diseases.

The list and exemption procedures for imports will also be developed by the Ministry of Health.

2) Reduced VAT Rates

The following VAT rates apply:

• 5% from January 1, 2026
• 10% from January 1, 2027

These rates apply to:

• The supply of medicines (other than those exempt from VAT), medical devices, components of medical devices, and technical assistive (compensatory) devices;
• Medical services provided by licensed healthcare entities, except for services exempt from VAT.

The relevant lists will be approved by the Ministry of Health.

10. Under the new Tax Code, on what date will a purchaser of goods, works, and services be entitled to claim input VAT based on an invoice? Has the VAT credit procedure changed?

Answer:

The new Tax Code provides that VAT shown on an invoice may be credited on the date of receipt of the goods, works, or services.

To claim the VAT credit, the VAT payer must make a corresponding mark in the Electronic Invoice Information System (IS ESF) indicating that the VAT amount under the electronic invoice is being claimed as input VAT.

11. Has the additional VAT credit incentive for agricultural producers and processors been retained?

Answer:

Yes. The additional VAT credit incentive for agricultural producers and processors has been retained.

However, due to the increase in the standard VAT rate to 16%, the additional VAT credit percentage has been increased from 70% to 80%.

12. Since 2019, gambling tax payers (casinos, slot machine halls, totalizators, and bookmakers) have also been VAT payers and subject to a special VAT calculation procedure. Are there any changes for this category?

Answer:

The new Tax Code changes the VAT treatment of gambling businesses.

From 2026, transactions related to gambling activities will be treated as non-taxable supplies for VAT purposes.

Similarly, activities in the lottery sector will also be treated as non-taxable supplies.

13. How will VAT treatment of the sale and lease of residential property change from 2026?

Answer:

Changes have been introduced regarding VAT exemptions for the sale and lease of housing.

VAT exemption will apply to the sale by a construction company of a residential building (or part thereof) where construction commenced and/or commissioning was completed before January 1, 2026.

VAT exemption will also apply to the lease of a residential building (or part thereof) under a long-term lease agreement with a purchase option, provided the agreement was concluded before January 1, 2026.

14. What changes have been made regarding the acquisition of works and services from non-residents?

Answer:

The procedure for recognizing the acquisition of works and services from non-residents remains unchanged.

However, to simplify tax administration, changes have been made regarding recognition and VAT crediting:

1. For acquisitions of works and services from non-residents, the VAT payer must issue an electronic invoice (ESF) to itself.
2. The ESF must be issued after payment of VAT on behalf of the non-resident to the state budget, but no later than five calendar days after such payment.
3. The VAT amount paid on behalf of the non-resident may be claimed as input VAT based on the issued ESF on the date the ESF is issued.
4. Why is it necessary to issue an ESF to oneself for services received from a non-resident?

Answer:

The requirement to issue an ESF for acquisitions of works and services from non-residents is related to the complexity of administering such transactions.

The absence of information in tax information systems prior to submission of the VAT Return (Form 300.00) results in inaccuracies regarding VAT credits and reduces the effectiveness of VAT desk audits.

The ESF for VAT paid on behalf of a non-resident must be issued to the taxpayer itself after payment of the VAT to the budget, but no later than five calendar days after such payment.

The taxpayer may then claim the VAT amount as input VAT based on the ESF on the date of its issuance.

This mechanism allows the VAT credit date to be clearly determined, simplifies administration, and reduces the number of desk-audit notifications issued by tax authorities.

16. If goods and services were purchased in the fourth quarter of 2025, but the ESF was issued in 2026, should VAT be credited at 12% or 16%?

Answer:

If the transaction date falls within the fourth quarter of 2025, the VAT rate applicable when issuing the ESF is the rate in force in 2025, namely 12%.

17. If medicines or medical services are purchased with VAT at 5%, can input VAT only be claimed at 5% even if the company's own taxable supplies are subject to VAT at 16%?

Answer:

The new Tax Code does not impose restrictions on claiming input VAT for goods and services used in activities subject to the standard VAT rate of 16%.

Accordingly, where medical services are acquired with VAT at 5% and used in making taxable supplies subject to VAT at 16%, the amount of input VAT available for credit is the VAT amount shown in the electronic invoice, i.e., the VAT calculated at 5%.

18. When applying the additional 80% VAT credit, will automated VAT control systems take into account that the VAT balance (e-Tamga, ESF database) only needs to cover VAT after deducting the 80% additional credit?

Answer:

The additional VAT credit is applied during the final VAT calculation in the VAT return and serves as a form of state support for working capital.

In contrast, the VAT balance is assessed at the time the ESF is issued.

The purpose of automated control is to prevent issuance of ESFs in the absence of legitimate VAT-bearing expenses (purchases from suppliers, imports of goods, or services acquired from non-residents).

Therefore, automated control will apply only to high-risk categories of taxpayers (such as newly registered or re-registered VAT payers, entities with minimal staffing, high-risk management profiles, etc.).

Accordingly, applying the additional VAT credit at the invoice issuance stage would not align with the objectives of either the additional VAT credit mechanism or automated control procedures.

19. Article 476 of the new Tax Code states:

“1. The following shall be exempt from VAT:

1. the sale of a residential building (part of a residential building), the construction of which commenced and/or the commissioning of which was completed before January 1, 2026...”

Why does the provision refer to commencement of construction or commissioning before January 1, 2026? Construction cannot be commissioned before it has begun.

Answer:

Under the current Tax Code:

• The sale of apartments is exempt from VAT;
• The sale of non-residential premises is subject to VAT.

Due to this exemption, a special procedure exists for accounting for input VAT on goods, works, and services used in constructing residential buildings containing both apartments and non-residential premises.

Under this procedure, input VAT may only be credited after the residential building has been commissioned, and only the portion attributable to non-residential premises is eligible for credit.

For this reason, the new Tax Code preserves the VAT exemption for apartments that form part of residential buildings where construction commenced or commissioning occurred before 2026.

The purpose of this approach is to preserve the VAT accounting treatment for construction projects started before 2026 or commissioned before 2026, where VAT has already been accounted for under the current Tax Code rules.

20. When issuing an ESF for services acquired from a non-resident and the service is invoiced in U.S. dollars, should the ESF be issued in tenge? Which exchange rate should be used?

Answer:

When a VAT payer issues an ESF in connection with the acquisition of works or services from a non-resident of the Republic of Kazakhstan, all values and amounts must be stated in the national currency of Kazakhstan (tenge).

The foreign currency transaction must be converted into tenge using the official exchange rate applicable on the date the taxable transaction occurs.

21. Will any restrictions be introduced regarding the withdrawal (cancellation) of ESFs by suppliers during the statute of limitations period? Bona fide companies often suffer from suppliers withdrawing ESFs.

Answer:

The draft Rules on the issuance of ESFs, the ESF form, and the format-logical controls of the ESF Information System introduce restrictions on the withdrawal of ESFs based on the applicable statute of limitations period.

 

Individual Income Tax (IIT) and Social Tax

22. What IIT rates are provided for in the new Tax Code?

Answer:

The new Tax Code introduces a progressive Individual Income Tax (IIT) rate structure.

For employee annual income exceeding 8,500 Monthly Calculation Indices (MCI) (approximately KZT 33.4 million), the IIT rate will be 15%.

For dividend income:

• Up to 230,000 MCI – 5%;
• Above 230,000 MCI – tax on income up to the 230,000 MCI threshold plus 15% on the excess amount.

For individual entrepreneurs applying the general taxation regime:

• Up to 230,000 MCI – 10%;
• Above 230,000 MCI – tax on income up to the threshold plus 15% on the excess.

Income of individuals engaged in private practice is taxed at 9%.

Income of peasant or farm households from the production, sale, or processing of their own agricultural products is taxed at 3% (previously a 70% reduction of IIT applied).

23. Does the progressive IIT scale above 8,500 MCI apply per employer or to aggregate income? How will it be administered?

Answer:

The progressive IIT scale for income exceeding 8,500 MCI applies to the aggregate taxable income of an individual.

However, IIT withheld at source is calculated by each tax agent separately based on the progressive scale applicable to income earned from that particular employer.

Individuals receiving income from multiple sources, including sources outside the Republic of Kazakhstan, exceeding 8,500 MCI during a calendar year must submit an Income and Assets Declaration reflecting such income and applying the progressive IIT rates.

If an individual receives employment income exceeding 8,500 MCI from a single source and the employer has already applied the increased IIT rate, the individual may be exempt from filing a declaration provided no other filing obligations exist.

24. What are the general approaches to IIT under the new Tax Code, particularly regarding tax deductions?

Answer:

To simplify tax compliance for individuals, the IIT section has been restructured to distinguish taxation administered by individuals themselves from taxation administered through tax agents.

Income classifications and corresponding reductions (including exempt income) have been introduced.

Tax incentives have been reviewed and reorganized according to income categories, including separate disclosure of capital gains from various types of property.

Tax Deductions

• A unified basic tax deduction of 30 MCI (approximately KZT 120,000) is introduced, requiring neither supporting documents nor filing of an income declaration.
• Existing social deductions are retained (for persons with disabilities, veterans, adoptive parents, guardians, etc.), as well as deductions for mandatory pension contributions and mandatory health insurance contributions.
• For persons with disabilities of Groups I and II, the deduction is increased to 5,000 MCI.
• Individuals who do not claim deductions through a tax agent may claim them against other income by filing an annual Income and Assets Declaration.

Additional Measures

• Pension payments, including lump-sum pension withdrawals, are exempt from taxation.
• To encourage individual investment activity, capital gains from securities transactions are calculated taking into account both gains and losses during the calendar year, as well as brokerage fees.

Differentiated IIT Rates

1. General Income (excluding income of entrepreneurs, private practitioners, farm households, and dividends)

• Up to 8,500 MCI (approximately KZT 35 million): 10%
• Above 8,500 MCI: 10% on income up to the threshold plus 15% on the excess

2. Individual Entrepreneurs under the General Tax Regime

• Up to 230,000 MCI (approximately KZT 960 million): 10%
• Above 230,000 MCI: 10% on income up to the threshold plus 15% on the excess

3. Dividend Income

• Up to 230,000 MCI (approximately KZT 960 million): 5%
• Above 230,000 MCI: 5% on income up to the threshold plus 15% on the excess

4. Income of Persons Engaged in Private Practice

• 9%

5. Income of Peasant/Farm Households from Own Agricultural Production

• 3%

25. When property owned by an Akimat is under trust management and dividends are distributed to the Akimat, is the 5% dividend tax applicable? If so, who is responsible for paying the tax?

Answer:

According to Article 363(3) of the Tax Code of the Republic of Kazakhstan (effective from 2026), dividend income is subject to the following progressive IIT rates:

• Up to 230,000 MCI – 5%;
• Above 230,000 MCI – tax calculated on income up to the threshold plus 15% on the excess.

Article 371(2)(6) includes dividends within an individual's annual income.

Article 377 defines taxable dividend income as dividends paid (or payable) under Article 13 of the Tax Code.

For purposes of Chapter 40, taxable dividend income also includes net income from trust management received by the settlor of a trust from a legal entity acting as trustee.

At the same time, Article 370(12) provides that net income from trust management received from an individual-resident trustee acting without registration as an individual entrepreneur is not considered income of the individual.

Special rules governing tax obligations when state institutions transfer property into trust management are established by Article 67 of the 2026 Tax Code.

26. What changes are introduced regarding Social Tax?

Answer:

The new Tax Code removes the linkage between Social Tax and Social Contributions.

As a result, a standalone Social Tax rate of 6% is established.

Special rates apply as follows:

• Agricultural producers: 8%
• Peasant and farm households under the general tax regime:
  • 6 MCI for the owner;
  • 3 MCI per employee.

Taxpayers applying special tax regimes are exempt from Social Tax, including:

• Self-employed individuals;
• Taxpayers using the simplified declaration regime;
• Peasant and farm households.

27. Have IIT rates changed?

Answer:

Yes. The new Tax Code introduces differentiated IIT rates depending on the type of income received.

All income, except income earned by persons engaged in private practice, is taxed according to the applicable progressive IIT scale.

Income of persons engaged in private practice (private notaries, attorneys, private bailiffs, and professional mediators) is taxed at 9%.

28. To which types of income does the progressive IIT scale apply?

Answer:

The following progressive IIT scale applies to all income except:

• Income of persons engaged in private practice;
• Income of individual entrepreneurs under the general taxation regime;
• Income of peasant/farm households under the general taxation regime;
• Dividend income.

The scale is:

• Up to 8,500 MCI per calendar year (approximately KZT 35 million): 10%;
• Above 8,500 MCI: 10% on income up to the threshold plus 15% on the excess.

Different progressive scales apply to entrepreneurs, farm households, and dividend income.

29. Does the progressive IIT scale apply to dividends?

Answer:

Yes.

Dividend income is taxed according to the following progressive scale:

• Up to 230,000 MCI per calendar year (approximately KZT 967 million): 5%;
• Above 230,000 MCI: 5% on income up to the threshold plus 15% on the excess.

30. Have IIT and Social Tax incentives for agricultural producers been retained?

Answer:

IIT

Peasant and farm households may reduce by 70% the amount of IIT calculated under the progressive rate scale on income derived from:

• Production and sale of self-produced agricultural products;
• Processing of self-produced agricultural products and sale of processed products.

Social Tax

A Social Tax rate of 1.8% applies to activities involving:

• Production and sale of self-produced agricultural products;
• Processing of self-produced agricultural products and sale of processed products.

Peasant and farm households calculate Social Tax as follows:

• For themselves: 0.6 MCI;
• For each employee: 0.3 MCI.

31. Which IIT tax incentives have been abolished?

Answer:

The following IIT exemptions and reductions have been eliminated:

1. Dividends received from a resident legal entity within 30,000 MCI (approximately KZT 110 million) per year;
2. Capital gains from property acquired by the state for public needs;
3. Payments up to 94 MCI per category made by a tax agent during a calendar year:
   • Reimbursement of medical expenses (excluding cosmetic procedures);
   • Employer-paid premiums under voluntary health insurance contracts;
   • Financial assistance upon the birth of a child;
4. Premiums paid by an individual under a cumulative life insurance contract with a term of at least three years, up to 320 MCI per year.

32. What IIT incentives are available for dividends?

Answer:

The new Tax Code allows a reduction of taxable dividend income derived from securities that, on the dividend accrual date, are included in the official list of stock exchanges operating within the Republic of Kazakhstan.

The incentive applies only to securities that were traded on the exchange during the calendar year and satisfy criteria established by the Government of Kazakhstan.

33. Has the ownership period for residential property, summer houses, garages, and similar assets been increased for purposes of capital gains taxation?

Answer:

Capital gains arise upon the sale or contribution to the charter capital of a legal entity of:

• Residential properties;
• Summer houses;
• Garages;
• Parking spaces;
• Storage units;
• Personal subsidiary farming properties,

located in Kazakhstan, if owned for less than two years from the date of registration of ownership rights.

This rule applies only to property acquired on or after January 1, 2026.

34. Are pension payments exempt from IIT?

Answer:

Yes.

Taxable pension income is reduced by:

1. Pension payments made by the Unified Accumulative Pension Fund (UAPF) and/or voluntary pension funds;
2. Pension payments made by the UAPF under international treaties ratified by Kazakhstan;
3. Lump-sum pension payments provided under social protection legislation;
4. Funeral payments made upon the death of an individual with pension savings in the UAPF or a voluntary pension fund.

Accordingly, these payments are effectively exempt from IIT.

35. What IIT benefits are provided for persons with disabilities?

Answer:

Individuals with Group I or Group II disabilities are entitled to a social tax deduction equal to 5,000 MCI.

For other categories:

• Group III disability;
• Children with disabilities;
• Parents, guardians, or custodians of children with disabilities until age 18;
• Parents, guardians, or custodians of persons recognized as disabled since childhood,

the annual deduction remains at 882 MCI (KZT 3,468,024 in 2025).

36. Have Social Tax rates changed?

Answer:

Yes.

The relationship between Social Tax and Social Contributions has been abolished. Social Tax is no longer reduced by the amount of social contributions paid.

The standard Social Tax rate is 6%, except as otherwise provided.

Agricultural Activities

A rate of 1.8% applies to activities involving:

• Production and sale of self-produced agricultural products;
• Processing of self-produced agricultural products and sale of processed products.

Individual Entrepreneurs and Private Practitioners

Social Tax is calculated as:

• 2 MCI for the taxpayer;
• 1 MCI for each employee.

Peasant and Farm Households

For agricultural activities:

• 6 MCI for the owner;
• 3 MCI for each employee.

37. What new measures for socially vulnerable groups are provided in the new Tax Code?

Answer:

The Government conducted calculations regarding the impact on socially vulnerable groups.

As previously noted, the increase in the VAT rate is expected to contribute approximately 2.3 percentage points to inflation. This will require indexation of pensions, social benefits, and wages.

Key measures include:

Persons with Disabilities

For persons with Group I and Group II disabilities, the IIT-exempt threshold is increased from 882 MCI (approximately KZT 289,000 per month) to 5,000 MCI (approximately KZT 1.6 million per month).

This measure is expected to leave approximately KZT 12 billion annually in the hands of around 350,000 taxpayers within this category.

Pensioners

Citizens are exempt from IIT on pension payments received from the Unified Accumulative Pension Fund (UAPF).

Vehicle Owners

Vehicle tax is reduced:

• By 30% for vehicles older than 10 years;
• By 50% for vehicles older than 20 years.

The reduction applies to approximately 4 million vehicles.

Low-Income Employees

As part of the progressive taxation framework, the standard tax-free salary deduction has been increased.

As a result, employees earning up to approximately KZT 140,000 per month will not pay IIT.

According to reporting data, this covers approximately 53% of all employees, or more than 3.8 million people.

The total amount retained by this category of employees is estimated to exceed KZT 90 billion annually.

 

Special Tax Regimes (STR)

38. There has been extensive discussion about special tax regimes. What has ultimately changed in the new Tax Code?

Answer:

Special tax regimes are designed to simplify the calculation and payment of certain taxes, as well as the submission of tax reporting, for specific categories of taxpayers.

The current Tax Code provides for seven special tax regimes (STRs):

• Patent-based STR;
• Simplified Declaration STR;
• STR using a special mobile application;
• STR using a fixed deduction;
• Retail Tax STR;
• STR for peasant or farming households;
• STR for agricultural producers and agricultural cooperatives.

The new Tax Code optimizes these into three STRs:

1. For self-employed individuals;
2. Based on a simplified declaration;
3. For peasant or farming households.

STR for Self-Employed Individuals

This regime may be applied by individuals who:

1. Are not individual entrepreneurs;
2. Do not employ hired workers;
3. Carry out activities for which this STR is permitted (the list will be approved by the Government of the Republic of Kazakhstan);
4. Have monthly income not exceeding 300 MCI (approximately KZT 1.2 million in 2026).

Such individuals are exempt from Personal Income Tax (PIT) and pay only social contributions amounting to 4% of income, including:

• 2% mandatory pension contributions (MPC);
• 1% social insurance contributions;
• 1% mandatory social health insurance contributions.

To maximize simplicity, obligations will be fulfilled through a special mobile application where monthly income is recorded and social contributions are calculated automatically.

For individuals operating through internet platforms, platform operators will calculate and remit social contributions. Those operating in areas without telecommunications networks will calculate and pay contributions independently.

STR Based on a Simplified Declaration

This regime combines the current Simplified Declaration regime and Retail Tax regime.

It may be applied by taxpayers who:

1. Have annual income not exceeding 600,000 MCI (approximately KZT 2.5 billion in 2026), with no limitation on the number of employees;
2. Conduct activities not included in the list of prohibited activities established by the Government.

The following may not apply this regime:

1. Legal entities in which other legal entities own more than 25%;
2. Legal entities whose founder or participant is simultaneously a founder or participant of another legal entity applying an STR;
3. Legal entities whose founder or participant personally applies an STR;
4. Taxpayers (individuals or entrepreneurs) who are founders or participants of legal entities applying an STR;
5. Structural subdivisions of legal entities;
6. Related parties (as defined in Article 14(1)(1)-(8) of the Tax Code) to taxpayers operating under the general taxation regime;
7. Non-profit organizations;
8. Participants of special economic zones, industrial zones, and Astana Hub;
9. Taxpayers conducting activities under joint activity agreements.

The PIT/CIT rate is 4%, with local representative bodies (maslikhats) authorized to increase or decrease the rate by up to 50%.

Taxable income may be reduced by payroll expenses if annual business income exceeds 24,000 MCI (approximately KZT 99.1 million in 2026).

Taxpayers applying this regime are exempt from:

• VAT;
• Social tax.

STR for Peasant or Farming Households

The current regime for peasant and farming households is retained.

However, due to the abolition of the Unified Land Tax, tax will be paid in the form of PIT at a rate of 0.5%.

39. Who may apply the special tax regime for self-employed individuals?

Answer:

To legalize and simplify tax compliance for individuals whose monthly income does not exceed 300 MCI (approximately KZT 1.3 million), the Tax Code introduces a new STR for self-employed individuals.

This regime may be used by taxpayers who currently:

• Apply the patent-based STR;
• Use the special mobile application regime;
• Work through platform employment arrangements;

as well as other individuals who meet the following criteria:

• Are not registered as individual entrepreneurs;
• Do not employ hired workers;
• Conduct activities permitted under a Government-approved list.

The key feature of the regime is that participants are:

• Exempt from PIT;
• Required to pay only social contributions totaling 4% of income (MPC, employer pension contributions, social insurance, and health insurance at 1% each);
• Exempt from registering as individual entrepreneurs.

40. Please describe the special tax regime for self-employed individuals. Who is it intended for and what are its advantages?

Answer:

To support individuals with modest or occasional income who operate without hired employees, including through internet platforms, the new Tax Code introduces a special tax regime for self-employed persons.

Key advantages include:

1. No requirement to register as an individual entrepreneur;
2. Exemption from VAT;
3. Full exemption from income tax.

The only obligation is payment of social contributions equal to 4% of income (1% each for MPC, employer pension contributions, social insurance, and health insurance), ensuring access to:

• Pension coverage;
• Health insurance;
• Social insurance protection.

A special mobile application will allow users to:

• Issue receipts for services rendered;
• Automatically maintain a monthly income register;
• Automatically calculate social contribution obligations.

For self-employed persons working through internet platforms, platform operators will withhold and remit social contributions.

Persons operating in areas without telecommunications networks must fulfill these obligations independently.

41. What are the key features of the simplified declaration tax regime?

Answer:

Under the new Tax Code:

• The annual income limit remains 600,000 MCI (approximately KZT 2.5 billion);
• Restrictions on the number of employees are eliminated;
• The regime applies to all activities except prohibited activities designated by the Government;
• A PIT/CIT rate of 4% is established, with maslikhats authorized to adjust the rate by up to ±50%;
• Taxable income may be reduced by payroll expenses if annual business income exceeds 24,000 MCI (approximately KZT 100 million).

Taxpayers applying this regime are not subject to:

• VAT;
• Social tax.

42. Does the simplified declaration regime apply to B2B transactions?

Answer:

Yes. The regime applies to both:

• B2C transactions;
• B2B transactions.

For simplicity, a single 4% tax rate applies to income received during the tax period, regardless of whether the transaction is B2B or B2C.

Local representative bodies may increase or decrease this rate by up to 50%.

43. Why is there a restriction on deducting expenses for CIT purposes in transactions with taxpayers using the simplified declaration regime?

Answer:

The restriction is intended to prevent abuse by counterparties that use the simplified declaration regime to minimize tax liabilities through:

• Artificial inflation of expenses;
• Supply-chain arrangements;
• Fictitious transactions.

44. Why are maslikhats granted the authority to adjust the tax rate by up to 50%?

Answer:

The simplified declaration regime establishes a base tax rate of 4%, with the possibility for maslikhats to increase or decrease it by up to 50%.

Since over 90% of registered taxpayers currently use special tax regimes, revenues from these taxpayers are significant for many regions.

Granting this authority allows regional governments to:

• Reflect local economic conditions;
• Consider entrepreneurial activity levels;
• Address social priorities;
• Ensure flexibility in tax policy;
• Distribute the tax burden more effectively according to regional needs.

45. Who may reduce taxable income by payroll expenses under the simplified declaration regime?

Answer:

To encourage business growth, employment formalization, and transparent labor relations, the new Tax Code allows taxpayers applying the simplified declaration regime to reduce the taxable base by payroll expenses once annual income exceeds 24,000 MCI (approximately KZT 100 million in 2026).

The adjustment becomes available from the moment the taxpayer's income exceeds this threshold.

46. Can the payroll deduction under the simplified declaration regime be applied in full?

Answer:

The deduction is tied to the taxpayer's income, not to payroll itself.

Taxable income may be reduced by payroll expenses only after annual income exceeds 24,000 MCI (approximately KZT 100 million in 2026).

Therefore, the threshold concerns business income rather than the amount of payroll.

47. Under the new Tax Code, if an LLP or entrepreneur purchases services from a self-employed person applying the self-employed STR, must PIT be withheld at source?

Answer:

Persons applying the self-employed STR are exempt from PIT and pay only social contributions amounting to 4% of income.

To simplify compliance, they must use a special mobile application that:

• Issues receipts for services rendered;
• Maintains an income register;
• Automatically calculates social contributions.

Accordingly, when a self-employed individual provides services, they must issue a receipt through the mobile application confirming the transaction with the LLP or entrepreneur.

In this case, the self-employed individual independently fulfills all tax obligations related to the income received.

Additionally, property income subject to self-assessment includes income received by an individual who is not an entrepreneur from leasing property to persons who are not tax agents.

Therefore, if the individual is neither self-employed nor registered as an entrepreneur, the obligation to calculate, withhold, and remit tax on rental income paid by a tax agent rests with the tax agent.

48. What changes are предусмотрены for taxpayers applying the STR for peasant or farming households?

Answer:

The existing special tax regime for peasant and farming households is retained.

However, due to the abolition of the Unified Land Tax (ULT), such households will pay PIT instead of ULT under the same conditions and at the same rate of 0.5% of income.

49. Which special tax regime may be applied by taxpayers currently using the Retail Tax STR?

Answer:

The current Simplified Declaration STR and Retail Tax STR are merged into a single Simplified Declaration STR with the following conditions:

1. Annual income not exceeding 600,000 MCI (approximately KZT 2.5 billion);
2. Activities not included in the Government's list of prohibited activities.

The following are not eligible:

1. Legal entities with more than 25% ownership by other legal entities;
2. Legal entities whose founders or participants are simultaneously founders or participants of another legal entity applying an STR;
3. Legal entities whose founders or participants personally apply an STR;
4. Taxpayers who are founders or participants of legal entities applying an STR;
5. Non-profit organizations;
6. Participants of special economic zones, industrial zones, and Astana Hub;
7. Taxpayers operating under joint activity agreements.

If the taxpayer satisfies these conditions, they may apply the Simplified Declaration STR.

50. What tax rate applies under the simplified declaration regime and from which taxes are taxpayers exempt?

Answer:

Under the Simplified Declaration STR:

• The PIT/CIT rate is 4%;
• Local representative bodies may reduce or increase the rate by up to 50%.

Additionally, the taxable base may be reduced by payroll expenses if annual income exceeds 24,000 MCI (approximately KZT 100 million).

Taxpayers applying this regime are exempt from:

• Social tax;
•  

51. How will taxpayers currently applying special tax regimes transition to the new regimes?

Answer:

To simplify the transition, the new Tax Code contains transitional provisions under which:

• Taxpayers operating exclusively through internet platforms will be automatically deregistered as individual entrepreneurs and transferred to the self-employed regime;
• Individual entrepreneurs applying the patent-based regime or the special mobile application regime must deregister as individual entrepreneurs in order to move to the self-employed regime (provided they meet the eligibility criteria).

The self-employed regime will be considered selected:

• In the month when receipts are first generated through the special mobile application;
• For persons operating in areas without telecommunications networks, in the period specified in payment documents confirming payment of social contributions.

Peasant and farming households currently applying the STR for farming households will be automatically transferred to the new farming household regime by the tax authorities.

Taxpayers not covered by these automatic transition provisions must submit a notification indicating the taxation regime they wish to apply.

 

Universal Declaration

52. What approach does the new Tax Code provide regarding universal declaration?

Answer:

The new Tax Code establishes an obligation to submit a Declaration of Assets and Liabilities (Form 250.00) for the following persons:

• Citizens and residents of the Republic of Kazakhstan who own property abroad;
• Candidates for elected positions, public offices, and equivalent positions;
• Citizens and residents of Kazakhstan who possess digital assets;
• Persons engaged in private practice.

The obligation to submit an Income and Property Declaration (Form 270.00) applies to:

• Civil servants and persons equated to them (including executives and founders of quasi-public sector entities) and their spouses;
• Major shareholders of banks, securities market participants, and insurance organizations, and their spouses;
• Managers and founders (participants) of commercial organizations (for joint-stock companies, those holding more than 10% of voting shares) and their spouses;
• Persons engaged in private practice;
• Persons owning property abroad;
• Persons who received income subject to self-assessment taxation, except income of individual entrepreneurs;
• Persons holding funds in foreign bank accounts exceeding 1,000 Monthly Calculation Indexes (MCI);
• Persons who acquired high-value property with a total value exceeding 20,000 MCI, both in Kazakhstan and abroad.

This approach reduces the declaration burden on citizens who do not own property abroad and decreases the number of violations related to declaration filing.

53. Who is exempt from filing the initial declaration under the fourth stage of universal declaration in 2025?

Answer:

Starting January 1, 2025, the remaining categories of the population included in the fourth stage of universal declaration are exempt from mandatory declaration, including:

• Pensioners;
• Employees of private-sector organizations;
• Students;
• Homemakers; and others.

The exemption does not apply to:

• Persons owning property abroad;
• Spouses of civil servants and persons equated to them;
• Other categories specifically required to declare.

54. Which categories of individuals must submit the Initial Declaration of Assets and Liabilities (Form 250.00) in 2025?

Answer:

From January 1, 2025, the following persons must submit Form 250.00:

1. Candidates for elected and public positions and their spouses;
2. Persons applying for the status of major participant in banks, securities market entities, and insurance organizations, and their spouses;
3. Persons engaged in private practice (notaries, lawyers, private bailiffs, mediators);
4. Citizens and residents of Kazakhstan who own digital assets;
5. Citizens and residents of Kazakhstan who own property abroad, including:
   • Real estate, vehicles, land;
   • Funds in foreign bank accounts exceeding a total of 1,000 MCI;
   • Investment gold;
   • Ownership interests in foreign companies;
   • Participation interests in housing construction projects;
   • Securities and derivative financial instruments issued by foreign entities;
   • Funds held in foreign brokerage accounts;
   • Intellectual property and copyright objects;
   • Accounts receivable/payable involving other persons (with supporting documents);
   • Other property valued above 1,000 MCI (if valuation exists).

55. What information must be reported in the Declaration of Assets and Liabilities (Form 250.00)?

Answer:

The declaration is intended to report information about:

• Property located outside Kazakhstan, rights to which or transactions involving which are subject to registration, including:
  • Real estate;
  • Land plots and land shares;
  • Aircraft and sea vessels;
  • Vehicles, special machinery and trailers;
  • Foreign bank accounts exceeding 1,000 MCI in aggregate.

Additionally, property located both in Kazakhstan and abroad:

• Participation interests in construction projects;
• Equity interests in legal entities;
• Securities;
• Digital assets;
• Investment gold;
• Intellectual property and copyrights;
• Funds in foreign brokerage accounts;
• Cash holdings up to 10,000 MCI;
• Accounts receivable and payable;
• Other property valued above 1,000 MCI.

56. Which categories of individuals must submit the Income and Property Declaration (Form 270.00) in 2025?

Answer:

The following persons must submit Form 270.00:

1. Civil servants and persons equated to them, and their spouses;
2. Major participants in banks, securities market entities, and insurance organizations, and their spouses;
3. Managers and founders (participants) of quasi-public sector entities and legal entities holding more than 10% ownership interests (or shares), and their spouses;
4. Persons engaged in private practice;
5. Persons receiving income subject to self-assessment taxation (rental income, foreign bank interest, digital asset transactions, and other income not taxed at source), excluding entrepreneurial income;
6. Persons holding funds in foreign bank accounts exceeding 1,000 MCI;
7. Persons owning assets abroad;
8. Persons owning digital assets;
9. Persons who acquired property during the reporting year with a total value exceeding 20,000 MCI, including property acquired abroad;
10. Persons who submitted an application to a tax agent for preliminary tax deductions.
11. What information must be disclosed in the Income and Property Declaration (Form 270.00)?

Answer:

The declaration is intended to disclose:

1. Income subject to self-assessment taxation;
2. Tax deductions;
3. Acquisition and/or disposal of property outside Kazakhstan, including transfers free of charge;
4. Claims for crediting or refunding excess PIT;
5. Funds in foreign bank accounts exceeding 1,000 MCI;
6. Accounts receivable and payable;
7. Property owned as of December 31 of the reporting year, including:
   • Property subject to registration in a foreign state;
   • Securities issued by foreign entities;
   • Digital assets;
   • Investment gold;
   • Ownership interests in foreign legal entities.

58. Have the deadlines for filing declarations changed?

Answer:

No, the filing deadlines remain unchanged.

• Form 250.00 (Declaration of Assets and Liabilities): no later than September 15 of the year in which the filing obligation arises.
• Form 270.00 (Income and Property Declaration): no later than September 15 of the year following the reporting calendar year.

Declarations are submitted at the taxpayer's place of residence.

59. What methods are available for submitting declarations?

Answer:

Electronically through:

• Taxpayer Cabinet (cabinet.salyk.kz);
• e-Government Portal (egov.kz);
• Mobile applications:
  • e-Salyq Azamat;
  • eGov Mobile;
  • qoldau.kz;
  • Halyk Bank;
  • Bank CenterCredit;
  • kz.

On paper:

• In person at State Revenue authorities;
• Through Public Service Centers (PSC/CON);
• By registered mail.

60. Which declarations must persons engaged in private practice submit in 2025, and what are the tax payment deadlines?

Answer:

Persons engaged in private practice must submit:

• Initial Declaration of Assets and Liabilities (Form 250.00);
• Annual Income and Property Declaration (Form 270.00).

Due to universal declaration, the PIT Declaration (Form 240.00) is abolished.

Tax payment rules change as follows:

• Before 2025: PIT paid monthly.
• Starting from 2025: PIT paid annually, no later than 10 calendar days after the filing deadline of Form 270.00 (i.e., by September 25).

61. If a private practitioner receives a notice requiring additional declarations for 2022–2023, which form should be submitted? What about a liquidation declaration?

Answer:

• For additional declarations covering 2022–2023, Form 00 must be submitted.
• Beginning with reporting for 2024 (submitted in 2025), Form 00 applies.

Since Form 270.00 currently does not contain a "liquidation declaration" type, liquidation declarations must still be submitted using Form 240.00.

Starting from 2026, Form 270.00 will include a liquidation declaration option.

62. What liability applies for late filing or submission of inaccurate information?

Answer:

Under Article 272 of the Code of Administrative Offenses:

Late submission of tax reporting:

• First violation: warning;
• Repeated violation within one year: fine of 15 MCI (KZT 58,980).

Submission of incomplete or inaccurate information:

• First violation: warning;
• Repeated violation within one year: fine of 3 MCI (KZT 11,796).

Concealment of taxable objects (Article 275):

• First violation: fine of 200% of unpaid taxes;
• Repeated violation within one year: fine of 300% of unpaid taxes.

63. Are employees of quasi-public sector companies exempt from filing annual declarations starting in 2026?

Answer:

According to Article 633 of the Tax Code, Form 270.00 must be submitted by residents of Kazakhstan who meet at least one of the specified conditions during the reporting year, including:

• Persons required to file declarations under anti-corruption legislation;
• Major shareholders of financial institutions and their spouses;
• Managers and founders holding more than 10% ownership interests and their spouses;
• Persons engaged in private practice;
• Persons receiving income subject to self-assessment;
• Persons with foreign bank accounts exceeding 1,000 MCI;
• Persons owning foreign property;
• Persons owning digital assets;
• Persons acquiring property exceeding 20,000 MCI;
• Persons claiming preliminary tax deductions.

Therefore, if an employee of a quasi-public sector entity does not meet any of these criteria and is not considered a person equated to public officials, they are not required to submit Form 270.00.

For reference, under the Law "On Combating Corruption," persons equated to public officials include those performing managerial functions in state organizations or quasi-public sector entities, procurement decision-makers, and persons responsible for state-funded projects at or above the level of head of an independent structural division.

64. If a person purchases real estate abroad after filing Form 250.00, how should it be reflected in Form 270.00?

Answer:

Under Article 633 of the Tax Code, residents who own foreign property as of December 31 of the reporting year must submit Form 270.00.

According to Article 634, Form 270.00 must include information about:

1. Acquisition and/or disposal of foreign property (reported in Appendix 4, Form 270.04, Section B), including:
   • Acquisition/disposal method;
   • Type of property;
   • Quantity;
   • Property identification number or contract number;
   • Date of registration;
   • Identification number of the transferor/transferee;
   • Country code of registration.
2. Property owned as of December 31 (reported in Appendix 4, Form 270.04, Section E), including:
   • Type of property;
   • Identification number;
   • Country of registration;
   • Property address.

Therefore, if a taxpayer acquires foreign property after submitting Form 250.00, they must disclose such property in Form 270.00 for the relevant reporting period and provide the required information described above.

 

 

Taxation of Subsoil Users

65. Given that there have been no major new discoveries in the country, does the new Tax Code provide any incentives for geological exploration?

Answer:

The new Tax Code allows exploration expenses incurred under exploration contracts to be transferred for Corporate Income Tax (CIT) purposes to existing contracts where mineral extraction is already taking place, or to non-contractual activities. These provisions also apply to unsuccessful exploration projects, the expenses of which were previously not deductible.

In addition, the current incentive exempting new projects from the Mineral Extraction Tax (MET) for five years has been retained, provided extraction commenced after January 1, 2023.

These measures are expected to significantly increase investment in geological exploration and contribute positively to replenishing the country's mineral resource base.

66. What incentives does the new Tax Code provide for mining companies engaged in mineral processing?

Answer:

To encourage the establishment of new processing facilities, the new Tax Code introduces several incentives under a Mineral Processing Agreement for Solid Minerals:

• Exemption from Corporate Income Tax and land tax for 10 years;
• Exemption from property tax for 8 years;
• Exemption from VAT on imported equipment and customs duties on imported equipment included in an approved list.

These incentives are intended to stimulate the construction of ore-processing plants and metallurgical facilities within both contractual and non-contractual activities of subsoil users.

67. In many countries with significant mineral reserves, royalties are used instead of a Mineral Extraction Tax. Has Kazakhstan introduced royalties?

Answer:

The new Tax Code introduces royalties effective January 1, 2027, for new projects involving the exploration and extraction of solid minerals.

The main difference between royalties and the current MET is that royalties will be payable after the sale of solid minerals, whereas MET is payable immediately after extraction, regardless of whether the minerals have been sold.

The proposed royalty rates vary depending on the level of processing:

• Ore – 13%;
• Concentrates – 10%;
• Metals – 7%.

These rates generally correspond to the current tax burden under MET.

The deferred implementation is due to the need for industry-specific measures, including the establishment of independent laboratories to assess mineral content and the introduction of appropriate regulatory mechanisms.

68. Does the new Tax Code provide support measures for mature oil and gas fields, many of which have been operating since the 1970s and require substantial investment to maintain production levels?

Answer:

For depleted oil and gas fields (with depletion exceeding 70% and water cut exceeding 85%), the new Tax Code allows the application of the Alternative Subsoil Use Tax (ASUT), provided certain reciprocal obligations are met, including directing tax savings toward production activities and regional social development.

ASUT replaces:

• Mineral Extraction Tax (MET);
• Historical cost payments;
• Excess profits tax;
• Export rent tax.

Overall, ASUT is similar to Corporate Income Tax and becomes payable only when taxable income exists and oil prices exceed USD 50 per barrel.

This approach reflects the fact that many major fields (including Uzen, Kumkol, Kenkiyak and others) have passed their peak production stage and require significant investment to sustain production and preserve jobs.

69. Are support measures provided for mining projects approaching or reaching depletion, particularly in single-industry towns where employment largely depends on mining activities?

Answer:

A number of major mining projects that previously operated through open-pit extraction (such as the Irtysh polymetallic deposit and Vasilkovskoye gold deposit) have reached a critical stage of depletion. Continued extraction requires underground mining operations involving substantial capital investment.

To support such capital-intensive projects, the new Tax Code introduces a mechanism providing exemption from MET until an Internal Rate of Return (IRR) of 15% is achieved, but for no more than five years, provided the following commitments are fulfilled:

• Investment of at least 3 million MCI in the allocated section of the deposit;
• Retention of at least 50% of jobs;
• Maintenance of wages at the industry-average level.

The incentive is applied through the allocation of a separate section of the deposit (with corresponding amendments to the Subsoil Code) and requires separate accounting.

Inclusion in the list of eligible projects must be approved by the State Commission for Economic Modernization and the Investment Council (Investment Headquarters).

70. Significant amounts of waste (low-grade ore, slag, sludge, etc.) remain after subsoil operations. Are there plans to encourage their processing?

Answer:

The new Tax Code introduces several incentives for Technogenic Mineral Formations (TMFs):

• A tenfold reduction in MET rates on minerals extracted from TMFs;
• Application of fixed MET rates applicable to common minerals (0.02 MCI per ton) when TMFs are used for:
  • Construction of roads and railways;
  • Hydraulic engineering structures;
  • Remediation of subsoil-use impacts;
• Changing the tax base from extracted minerals to sold minerals recovered from TMFs.

Previously, minerals extracted from TMFs were taxed at standard MET rates, which did not provide sufficient incentives. The reduced rates are expected to encourage the recovery and utilization of additional mineral resources.

71. Uranium prices have increased significantly in recent years. Are additional taxes planned for uranium mining companies in Kazakhstan?

Answer:

Uranium is one of Kazakhstan's strategic natural resources. The country possesses approximately 553 thousand tons of explored uranium reserves and remains the world's leading producer, with annual production of around 20 thousand tons.

Given that uranium prices have increased nearly fourfold over the past five years—from USD 24 to USD 80 per pound, with peaks reaching USD 107 per pound—the new Tax Code introduces progressive MET rates based on:

• Annual production volumes;
• Global uranium prices.

In other words, the more uranium a company produces, the higher its tax burden. Additional rates apply when uranium prices exceed USD 70 per pound.

This measure is expected to capture part of the windfall profits earned by uranium producers (up to KZT 140 billion annually) and support the extension of the operational life of existing deposits.

Previously, uranium MET rates were fixed at:

• 6% in 2024;
• 9% in 2025.

72. Are additional taxes planned for companies extracting other minerals whose prices have also risen?

Answer:

Kazakhstan currently ranks:

• 10th globally in explored gold reserves;
• 6th globally in gold production.

Global gold and silver prices have shown steady growth in recent years:

• Gold: from USD 1,393 per ounce in 2019 to USD 2,859 per ounce in 2025;
• Silver: from USD 16 to USD 32 per ounce.

Under the current fixed MET rate of 7.5% on gold and silver, subsoil users generate substantial windfall profits that are not sufficiently shared with the state.

Therefore, the new Tax Code introduces differentiated MET rates for gold and silver based on prices on the London Metal Exchange.

This measure is expected to capture part of the windfall profits of precious metals producers (up to KZT 80 billion annually).

At present, no differentiated MET rates are planned for other minerals.

73. Will expenses related to establishing a pledged bank deposit for subsoil-use remediation be deductible for tax purposes?

Answer:

The Tax Code allows deductions for Corporate Income Tax purposes for expenses related to establishing a pledged bank deposit intended to finance remediation of subsoil-use impacts in the hydrocarbons sector, similar to the existing liquidation fund mechanism.

These provisions were introduced to harmonize tax legislation with industry regulations requiring the establishment of a pledged bank deposit as security for remediation obligations.

Contributions to such deposits will be deductible under the same rules applicable to liquidation funds.

If all or part of the pledged deposit is subsequently returned, the returned amount must be included in taxable annual income.

The amount and procedure for such contributions are established by the project's basic design documents in accordance with subsoil-use legislation.

For other minerals where pledged bank deposits are also required, the issue remains under consideration due to sector-specific regulatory features.

74. What other changes in the new Tax Code affect subsoil users?

Answer:

The new Tax Code abolishes the provision that allowed subsoil users extracting solid minerals to use a fixed exchange rate when determining the value of minerals sold in foreign currency for MET purposes.

Going forward, subsoil users must use the exchange rate applicable on the date ownership of the minerals is transferred.

This change is intended to eliminate tax disputes and improve fairness and certainty in taxation.

75. Can R&D expenses paid directly to the state under subsoil-use obligations still qualify for the 200% tax uplift deduction?

Answer:

According to Article 337(1)(6) of the Tax Code, taxpayers are entitled to reduce taxable income by 200% of deductible expenses incurred under Article 269 for:

• Scientific research, scientific and technical, and/or experimental design work (R&D) related to the creation of industrial property, including projects protected by intellectual property rights;
• Acquisition of exclusive intellectual property rights from universities, scientific organizations, autonomous educational institutions, and startup companies under licensing or assignment agreements for commercialization purposes.

These provisions apply only when such activities are conducted and/or their results are implemented within the territory of Kazakhstan.

Evidence of R&D activities or implementation of results must be supported by an implementation certificate approved in accordance with procedures established by the authorized science authority in coordination with relevant sectoral authorities.

Accordingly, the new Tax Code contains an exhaustive list of circumstances and conditions under which the 200% uplift may be applied to R&D expenses.

Furthermore, Articles 269 and 302 of the Tax Code, which govern the deductibility of R&D expenses, do not allow deductions for amounts paid into the state budget in fulfillment of contractual obligations under the Code on Subsoil and Subsoil Use.

 

 

Taxation of Non-Residents

76. What innovations does the new Tax Code introduce regarding the taxation of non-residents?

Answer:

The new Tax Code introduces the following changes concerning the taxation of non-residents:

1. Expansion of the list of non-resident income sourced in the Republic of Kazakhstan:

• The list of services provided by non-residents that are subject to taxation in Kazakhstan regardless of where the services are rendered has been expanded to include design, advertising, educational, and rating services.
• A new category of taxable income has been introduced: an unpaid loan granted by a Kazakhstan resident to a non-resident.

2. Changes to tax incentives for non-residents:
   Certain tax exemptions have been recognized as ineffective and have been partially abolished, including exemptions related to:

• Dividends received by non-residents;
• Capital gains income.

3. Changes in the application of international tax treaties:

• The chapter structure has been revised and simplified. Separate sections now cover:
• General provisions on international treaties;
• Provisions applicable to tax agents;
• Provisions applicable to permanent establishments.
• The wording of provisions related to the application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) has been simplified.
• New provisions have been introduced to facilitate the independent application of international treaties by tax agents by clearly defining circumstances that may result in improper treaty application.

4. Simplification of residency confirmation requirements:

• The Tax Code now allows the use of electronic certificates of tax residency to confirm a non-resident's residency status.

Tax Administration

77. The new Tax Code abolishes voluntary VAT deregistration. Does this mean that even if my turnover does not exceed the VAT registration threshold, I must remain a VAT payer? Why was this change introduced?

Answer:

Under the new Tax Code, VAT registration may be cancelled only on the following grounds:

• Transition from the general taxation regime to a special tax regime;
• Termination of business activities or liquidation of the VAT payer.

Voluntary VAT deregistration solely because turnover has not exceeded the VAT registration threshold is no longer permitted, as this mechanism allowed taxpayers to avoid fulfilling their tax obligations.

Therefore, the amount of turnover cannot serve as a basis for VAT deregistration.

78. The new Tax Code introduces an automated electronic invoice (e-Invoice/ESF) issuance control procedure. However, it does not specify which taxpayers will be subject to such control. Who will fall into this category?

Answer:

According to Article 139(1) of the new Tax Code, the categories of taxpayers subject to automated control will be approved by the authorized body (the Ministry of Finance of the Republic of Kazakhstan).

Automated control will apply to high-risk categories of taxpayers, including:

• Newly registered VAT payers;
• Re-registered VAT payers;
• Taxpayers with a minimal number of employees, and others.

The control period will last one year from the start of e-Invoice issuance. If regular tax payments are made for six consecutive months, the taxpayer will be removed from control.

79. Under automated e-Invoice control, will VAT overpayments existing as of January 1, 2026 (for example, exporter VAT credits on personal accounts) or any VAT prepayments be reflected in the balance of the control account?

Answer:

Since the category of taxpayers subject to control primarily includes newly registered and re-registered taxpayers (who generally do not have such balances), VAT overpayments as of January 1, 2026 will not be reflected in the control account balance.

Accordingly, exporters with existing VAT overpayments will not be subject to automated control.

80. Under the new Tax Code, can a taxpayer deregister from VAT if tax reporting is suspended in 2026?

Answer:

The new Tax Code provides only the following grounds for VAT deregistration:

• Transition from the general taxation regime to a special tax regime;
• Termination of activity or liquidation of the VAT payer.

Voluntary VAT deregistration due to turnover remaining below the VAT registration threshold is not allowed.

Therefore, suspension of tax reporting cannot serve as grounds for VAT deregistration.

81. During comparative control of e-Invoices, if an invoice is blocked, who removes the block: the local tax authority or the State Revenue Committee?

Answer:

Following comparative control, the taxpayer receives a notification requesting confirmation that the sale of goods, performance of work, or provision of services actually occurred.

If the taxpayer agrees that the transaction did not occur:

• The taxpayer withdraws the relevant e-Invoices and provides explanations for the withdrawal.

If the taxpayer disagrees:

• The taxpayer submits supporting explanations and copies of documents confirming the actual transaction.

Once the notification requirements are fulfilled, the State Revenue Authority at the taxpayer’s place of registration removes the suspension on e-Invoice issuance.

82. If the classification of taxpayers by high, medium, and low risk is abolished, how will companies choose suppliers to avoid losing deductions or VAT credits?

Answer:

The new Tax Code abolishes:

• Taxpayer classification by risk level (high, medium, low);
• Selection of taxpayers for periodic tax audits based on risk assessment.

Instead, a new concept called the Tax Risk Management System is introduced.

This system will:

• Identify specific tax risks;
• Apply preventive informational measures or mandatory corrective measures.

The focus shifts from assessing the taxpayer as a whole to identifying the risk of non-payment or underpayment of specific taxes.

Additionally, a new service is planned that will allow taxpayers to access non-confidential information about counterparties and independently assess their reliability.

83. What measures have been taken in the new Tax Code to reduce the number of taxes, fees, and charges?

Answer:

The new Tax Code provides the following reductions:

1. Taxes

• The Unified Land Tax is abolished.
• The number of taxes is reduced from 12 to 11.

2. Charges for the use of state resources and licenses

• The fee for licenses related to certain types of activities is abolished.
• Three separate charges are merged into one:
  • Forest and plant resources;
  • Wildlife resources;
  • Surface water resources.

These will be combined into a single Natural Resources Usage Fee.

As a result:

• The number of charges decreases from 10 to 7.
• The number of rates decreases from 374 to 323.

3. Fees

Six fees are abolished, including fees for:

• Registration and re-registration of medicines and medical devices;
• Registration of space objects and related rights;
• Registration of movable property pledges and ship mortgages;
• Registration of TV and radio channels, print publications, news agencies, and online media;
• Issuance of permits and approvals for banking and insurance market participants;
• Issuance of radio frequency spectrum permits for broadcasters.

As a result:

• Fee rates decrease from 310 to 276.

4. State Duties

Five state duties are abolished, including duties for:

• Intellectual property-related legal actions;
• Notarial acts;
• International freight transport permits;
• Seafarer identification documents and maritime certificates;
• Permits for import, export, and re-export of certain animal and plant species.

As a result:

• Duty rates decrease from 113 to 62.

84. What changes regarding tax audits are introduced by the new Tax Code?

Answer:

The new Tax Code provides for:

• Conducting only unscheduled tax audits, eliminating the distinction between scheduled and unscheduled audits.
• Comprehensive audits will not be conducted for taxpayers whose tax burden coefficient is at least 90% of the approved industry average.
• Most audit documents (except the audit order) may be delivered electronically through the taxpayer's online account.
• The statute of limitations is extended until the completion of an ongoing tax audit.
• Tax audits cannot be initiated within 30 calendar days before the expiration of the statute of limitations for the relevant tax period.
• Audit orders must be delivered within three business days after issuance.
• The Code establishes fundamental principles governing taxation and tax audits.
• Audit periods and extensions are reduced.
• Suspension of audits for small and micro-businesses is limited to no more than two times.
• Deadlines for responding to document requests during audits are reduced to 10 business days.

85. Articles 209 and 492 of the new Tax Code require invoices to be additionally verified using biometric data. Why is this necessary?

Answer:

The purpose of biometric verification is to prevent invoices from being signed by unauthorized individuals and to reduce transactions involving high-risk companies or persons not involved in the actual financial and business activities of a company.

Biometric identification is required when a taxpayer is identified as presenting a risk under the Tax Risk Management System pursuant to Article 93 of the Code.

In such cases:

• The taxpayer receives a notification through the e-Invoice Information System.
• Biometric identification must be completed by 11:59 PM on the day of invoice issuance.
• Identification is required once per day on which e-Invoices are issued.

86. Will the procedure for inclusion in and removal from the register of inactive taxpayers change under the new Tax Code?

Answer:

Under the new Tax Code:

A taxpayer is included in the register of inactive taxpayers if they fail to submit any tax return for 12 months after their most recent filing.

The previous differentiation by return type is abolished.

A taxpayer may be removed from the register by submitting an additional tax return for a period within the statute of limitations, provided the return is automatically recognized as filed with zero indicators.

Other changes include:

• Replacement of a tax authority order with a tax authority decision;
• Reduction of the removal period from five to three business days;
• Elimination of mandatory tax inspections of inactive taxpayers;
• Suspension of e-Invoice issuance within one business day after an individual entrepreneur is included in the register;
• Inclusion in the register of entities whose director or sole founder is also the director or sole founder of a VAT-registered legal entity.

87. What changes are introduced regarding compulsory termination of business activities?

Answer:

Under the new Tax Code, compulsory termination may apply only to a taxpayer who is not:

• A director or founder of another legal entity;
• A participant in a joint business venture.

Additional conditions include the taxpayer:

• Having unresolved or inadequately resolved notices regarding violations identified through desk audits or tax audits;
• Being subject to enforcement measures (asset seizure or restrictions) imposed by bailiffs or other authorized bodies;
• Being a party to export or import currency contracts where currency control procedures related to repatriation have not been completed;
• Having conducted payments or money transfers through bank accounts during the statute of limitations period.

88. Which secondary legal act will regulate the content requirements of cash register receipts?

Answer:

Requirements concerning the content of cash register receipts (mandatory details, structure, format, etc.) have been removed from the Tax Code.

They will now be established by a separate Ministry of Finance regulation titled:

"On Certain Issues Related to the Use of Cash Registers."

89. Will cash register software need updating if receipt requirements change?

Answer:

The Ministry of Finance has developed Data Transmission Protocol Version 2.0.3 for cash registers with data recording and transmission functions.

Currently, cash register software developers are testing the protocol on operators’ test platforms. Testing is expected to be completed by August 31.

Following completion of testing, taxpayers will be required to update or reprogram their cash registers within six months.

90. What changes are introduced regarding taxpayer accounts and payment records?

Answer:

The new Tax Code generally preserves the existing rules for maintaining taxpayer accounts and recording payments, including the statute of limitations for offsetting and refunding overpaid taxes.

However, to maintain accurate account balances, overpayments that can no longer be offset or refunded due to expiration of the limitation period will be written off.

91. Which tax reporting forms will be eliminated under the new Tax Code?

Answer:

Tax reporting will be reduced by approximately 30%, although additional mandatory disclosure fields (e.g., for tax incentives) will be introduced.

Key changes include:

• Property Tax Calculation Form 01 will be abolished if tax liabilities do not exceed KZT 1 million.
• Taxpayers with liabilities below KZT 1 million will file Property Tax Declaration Form 700.00 only once annually.
• Transport Tax Calculation Form 00 is abolished.
• Land Tax Calculation Form 01 is abolished.

The following forms are expected to be eliminated or integrated into other forms:

• 01
• 00
• 00
• 00
• 00
• 00
• 00
• 00
• 00
• 00
• 00
• 00

92. Will the format-logical control (FLC) rules used by tax authorities be published for taxpayers?

Answer:

Yes.

Format-logical control (FLC), which verifies the completeness and accuracy of tax reporting, is based on the rules for completing tax forms approved by the authorized body.

To assist taxpayers, the new Tax Code provides for publication of FLC requirements on the official website of the authorized authority (see Article 46(2)(2)).

93. Besides reducing tax reporting by 30%, what other innovations are introduced to reduce the burden on businesses?

Answer:

A major innovation is the automatic generation of zero tax returns.

If a taxpayer (legal entity, individual entrepreneur, or private practitioner) fails to submit a tax return by the deadline:

• The tax authority’s information system will automatically generate a zero return.
• The return will be considered filed with zero indicators.
• The taxpayer may later submit an additional return if necessary.

This mechanism is intended to assist taxpayers during:

• Emergencies;
• Internet outages;
• Other force majeure situations.

As a result, the following measures for late filing are abolished:

• Tax authority notices;
• Bank account seizures;
• Administrative fines.

In addition:

• Extensions of filing deadlines are abolished;
• Suspension of reporting obligations will be available through alternative mechanisms.

94. How can tax returns be corrected if the new Tax Code abolishes withdrawal of tax returns?

Answer:

Under the new Tax Code, tax returns generally cannot be withdrawn, except for the Application for Importation of Goods and Payment of Indirect Taxes (Form 328.00) within the Eurasian Economic Union framework.

Corrections will instead be made by:

• Filing an additional tax return; and/or
• Filing a tax return in response to a tax authority notification.

Detailed procedures will be established by a Ministry of Finance regulation entitled:

"On Certain Issues Related to the Submission of Tax Reporting."

95. What taxpayer support measures are provided under the service model of the new Tax Code?

Answer:

The primary objective of the service model is to reduce administrative costs for taxpayers, promote economic development, and improve tax collection.

The new Tax Code introduces the following service-oriented measures:

• Mobile service groups to assist individuals with disabilities and residents of remote settlements;
• Notifications through video, audio, and other technical means regarding upcoming tax obligations;
• Push notifications through banking applications regarding:
  • Suspension of reporting;
  • VAT registration requirements;
  • Changes in tax regimes;
• Informational and preventive notifications from tax authorities;
• Pre-completed tax returns for:
  • Small business taxpayers using special tax regimes;
  • Individuals participating in universal declaration, based on information already available to tax authorities.

As a result, the service model is expected to significantly reduce administrative burdens, allowing businesses to spend less time on paperwork, reporting, and disputes with government authorities, and more time on business development.

Miscellaneous

96. Are beneficiaries exempt from paying state duties in court for all cases and documents when acting as defendants?
    Answer:
    Yes. Beneficiaries are exempt from paying state duties in court in all cases and for all documents when acting as defendants. This includes veterans of the Great Patriotic War (World War II), persons equated to such veterans in terms of benefits, persons with disabilities, as well as one parent of a person with a disability from childhood or a child with a disability.
97. Are logging activities on forest areas affected by fires exempt from forest resource usage fees?
    Answer:
    Yes. State forest owners and persons granted forest use rights under the Forest Code of the Republic of Kazakhstan are exempt from paying forest resource usage fees for intermediate-use logging and other logging activities on areas affected by fires, provided that the burned area exceeds 100 hectares.
98. Are there reduced transport tax rates for older vehicles?
    Answer:
    Yes. For passenger vehicles with a service life exceeding:

• 10 years – a correction coefficient of 0.3 applies;
• 20 years – a correction coefficient of 0.5 applies.

99. Peasant and farming enterprises currently use pickup trucks in their operations, but under the current Tax Code they are not exempt from transport tax. Are there any changes in the new Tax Code regarding exemption of such vehicles?
    Answer:
    Yes. Peasant and farming enterprises are entitled to an exemption from transport tax for one pickup truck.
100. Which fees have been excluded from the Tax Code?
     Answer:
     The fee for the use of licenses for certain types of activities has been excluded from the new Tax Code.
101. Agricultural land plots that became part of urban boundaries due to changes in settlement borders are currently affected. Will the agricultural land tax rates be preserved for such land?
     Answer:
     Yes. The new Tax Code includes a provision allowing agricultural land located within settlement boundaries due to boundary changes to continue being taxed at agricultural land rates, provided that such land continues to be used for agricultural purposes.
102. What changes are предусмотрены in the new Tax Code regarding gambling business tax?
     Answer:
     The existing procedure for fulfilling tax obligations related to the gambling business tax remains unchanged.
103. What measures will be applied to foreign internet platforms that fail to complete conditional registration with the tax authorities of the Republic of Kazakhstan?
     Answer:
     According to the new Tax Code, foreign internet platforms operating in Kazakhstan must complete conditional registration with the tax authorities.

Failure to comply may result in administrative measures, including blocking access to internet resources and/or the platform itself.

Additionally, if discrepancies are identified during desk audits regarding taxes paid (for example, VAT), and such discrepancies are not corrected following an official notice, a decision may also be made to block the platform.

104. Will internet platforms be required to provide information about their activities?
     Answer:
     Yes. Under the new Tax Code, both domestic and foreign internet platforms are required to provide information on the sale of goods, works, and services conducted through their platforms.

This information must be submitted monthly to the authorized authority and will include data on sellers, sales volumes, and other transaction details.

This measure aims to ensure transparency in e-commerce and improve monitoring of participants’ tax obligations.

In addition, foreign internet platforms making payments to individuals who are residents of Kazakhstan will also be required to provide information about such payments.

This is necessary for desk audits of income earned through digital platforms (such as YouTube, TikTok, and others).

Luxury Tax

105. What does “luxury tax” mean?
     Answer:
     The new Tax Code does not introduce a separate “luxury tax” as such. However, it introduces specific taxation rules for assets that meet certain luxury criteria.
106. What assets fall under the “luxury tax”?
     Answer:
     For taxation purposes, the following are considered luxury assets:

• Automobiles with a purchase value of 18,000 Monthly Calculation Indexes (MCI) or more;
• Yachts and aircraft with a purchase value of 24,000 MCI or more;
• Alcoholic products valued at more than KZT 500,000;
• Tobacco products (cigars) valued at more than KZT 10,000;
• Real estate (apartments, residential houses, etc.) with a total aggregate value exceeding KZT 450 million (the value used is the taxable value, not the market value).

107. How is the “luxury tax” calculated?
     Answer:

• For automobiles, yachts, and aircraft, an excise tax of 10% of the purchase value is charged.
• For alcoholic products and tobacco products (cigars), an excise tax of 10% of the value in tenge per liter or per unit is charged upon import into Kazakhstan.
• For real estate, property tax is calculated at a rate of 2% of the aggregate value of all properties owned.

Additionally, local representative bodies may establish a luxury coefficient that increases the taxable value by up to 50%.

108. If I own several apartments and houses, will I have to pay the so-called “luxury tax”?
     Answer:
     Yes, if the total value of your property exceeds KZT 450 million (which is approximately 5.6 times lower than its market value), you will be subject to the luxury taxation rules.