Country：哈萨克斯坦 · Tax, Finance & Audit
Kazakhstan · Tax, Finance & Audit
Kazakhstan implemented a new Tax Code effective 1 January 2026, the most significant tax reform in years: simplified reporting (reporting reduced by 30%, tax types by 20%); VAT raised from 12% to 16%; CIT remains 20% (banks and gambling 25%); personal income tax moved from flat 10% to progressive rates; transfer pricing applies to all cross-border transactions (not only related parties); entities meeting size thresholds must undergo annual audit. The China-Kazakhstan tax treaty can reduce withholding taxes.
Key points
- CIT: standard 20%; banks and gambling 25%; agricultural producers 3% (preferential); social organizations in education/healthcare 5% in 2026, 10% from 2027.
- VAT: standard rate raised from 12% to 16% effective 2026; medical services 5% in 2026 and 10% in 2027; domestic books and publications exempt; agricultural producers enjoy 80% VAT add-on deduction; registration threshold is annual turnover above 10,000 MCI (2026 MCI = KZT 4,325, about KZT 43.25M / USD 154,000).
- PIT: from flat 10% to progressive rates; portion of annual income above 8,500 MCI taxed at 15%; dividends above 230,000 MCI taxed at 15%.
- Withholding tax (WHT, non-residents): dividends 15% (20% low-tax jurisdiction), interest 15% (20%), royalties 15% (20%); the China-Kazakhstan treaty usually reduces to 5-10%.
- Transfer pricing (TP): applies to all cross-border transactions and certain domestic transactions (among the most aggressive rules in the region); statutory method hierarchy prioritizes CUP; local file must be filed annually; CbCR threshold is consolidated revenue ≥ EUR 750 million; unilateral or bilateral APA available (max 3 years, no roll-back).
- Loss carryforward: up to 10 years.
- Priority investment projects (PIR): new production projects enjoy 10-year CIT and land tax exemption, 8-year property tax exemption, 5-year import duty exemption.
- Audit: entities meeting any two conditions for two consecutive years (revenue > EUR 5.7M, assets > EUR 2.85M, employees > 50) must undergo annual audit; foreign-invested enterprises commonly have annual audit requirements.
Procedure
- Register with the tax authority within 10 business days of incorporation (INN + OKPO) and choose a tax regime.
- Register for VAT once the threshold is met.
- File and pay WHT, VAT and social contributions monthly or quarterly; annual CIT return due by March 31 of the following year, top-up by April 10.
- Prepare transfer-pricing documentation for cross-border payments (dividends, interest, royalties); have master and local files ready to claim treaty benefits.
- Entities meeting size thresholds arrange annual financial statement audit and filing.
Hard requirements
- Tax registration and tax number (INN/OKPO).
- Transfer-pricing documentation (cross-border transactions, CUP-priority) and CbCR (group revenue ≥ EUR 750M).
- Annual audit (if size threshold met).
- Withholding tax filing and treaty-benefit documentation.
Costs
Accounting and tax filing agency fees (scale-dependent).Audit fees (revenue and complexity dependent).Transfer-pricing documentation and APA advisory fees.⏱ ⏱ Timeline：Tax registration within 10 business days; annual CIT return by March 31 of the following year; audit within months after the fiscal year-end⚠ Common risks
- VAT rises to 16% in 2026, directly raising compliance costs
- Transfer pricing applies to all cross-border transactions (including non-related parties); goods priced under strict CUP review, easily adjusted upward
- WHT on payments to low-tax jurisdictions rises to 20%; structure must avoid this
- New Tax Code just effective (2026-01); details and transition rules require counsel/accountant review
Handbook
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to：Tax filing, VAT registration, transfer pricing, audit and investment incentives for entities operating in Kazakhstan (under the new Tax Code effective 2026-01-01)
Prerequisites
- Legal-entity registration completed and tax registration obtained (INN+OKPO)
- Tax regime selected (general/simplified/single land tax)
- Accounting and tax agents in place
- Cross-border transactions and related-party structure mapped
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Complete tax registration (INN+OKPO) within 10 business days of registration and choose a tax regime Register with the tax authority and choose the applicable regime | Enterprise / tax agent | No more than 10 business days | Agency fees | Tax registration | BIN is auto-generated but active registration and regime selection are required Penalty：Late registration is a violation |
| 2 | Register for VAT once the threshold is met (annual turnover above 10,000 MCI) 2026 MCI = KZT 4,325; 10,000 MCI ≈ KZT 43.25M is the mandatory registration threshold; standard VAT rate 16% | Enterprise | Upon trigger | — | VAT registration | Medical industry 5% in 2026, 10% from 2027; domestic books and publications exempt Penalty：Fines for not registering above threshold |
| 3 | File and pay WHT, VAT and social contributions monthly or quarterly; annual CIT return by March 31 of the following year, top-up by April 10 Build a filing calendar and pay all taxes on time | Accountant | Monthly, quarterly, annual | Agency fees | Tax returns | Standard CIT rate 20%; banks and gambling 25% Penalty：Late fines and interest |
| 4 | Prepare TP documentation for cross-border payments (dividends, interest, royalties); treaty benefits require master and local files TP applies to all cross-border transactions (not only related parties); statutory method prioritizes CUP; local file filed annually | Tax and TP advisor | Continuous | TP advisory fees | TP local file, CbCR (group revenue ≥ EUR 750M) | Unilateral or bilateral APA available (max 3 years, no roll-back) Penalty：TP adjustments; WHT to low-tax jurisdictions rises to 20% |
| 5 | Claim China-Kazakhstan treaty benefits to reduce WHT (dividends, interest, royalties 5-10%) File for treaty benefit before payment under the China-Kazakhstan tax treaty | Enterprise | Before payment | — | Treaty benefit application | Non-treaty or low-tax jurisdiction rate is 15% or 20% Penalty：Without filing, 15%/20% withheld |
| 6 | Entities meeting size thresholds arrange annual financial statement audit Annual audit required for entities meeting any two conditions for two consecutive years (revenue > EUR 5.7M, assets > EUR 2.85M, employees > 50); foreign-invested enterprises commonly require annual audit | Auditor | Within months after fiscal year-end | Audit fees | Audit report | Loss carryforward up to 10 years Penalty：No audit constitutes a violation |
| 7 | Apply for tax incentives after PIR designation New production projects enjoy 10-year CIT and land tax exemption, 8-year property tax exemption, 5-year import duty exemption | Enterprise and Investment Committee | Before or during early investment | Application fees | PIR designation | Requires signing an investment agreement (see qualification dimension) Penalty：No incentives without designation |
✅ Self-check list
⚠ Common pitfalls
VAT raised to 16% in 2026 directly raising compliance costs影响：Cash flow and pricing pressure规避：Re-model pricing and cash flow
TP applies to all cross-border transactions (including non-related), strict CUP review影响：Taxable income easily adjusted upward规避：Complete TP documentation and pricing policy
WHT on payments to low-tax jurisdictions rises to 20%影响：Higher tax burden规避：Use treaty-country intermediary structure
New Tax Code just effective (2026-01); details and transition rules need review影响：Misapplied standards规避：Follow counsel/accountant opinions
Audit threshold (revenue/assets/employees) misjudged影响：Audit omission violation规避：Calculate two-year thresholds early
Treaty benefits not filed影响：WHT at 15%/20%规避：File before payment
📅 Ongoing post-incorporation obligations
- Monthly/quarterly WHT, VAT and social contribution filings
- Annual CIT filing (March 31) and top-up (April 10)
- Annual TP documentation and CbCR (if threshold met)
- Annual financial statement audit (if size threshold met)
- Loss carryforward (up to 10 years) records
- Monthly employee PIT and social contributions withheld
🔗 Official portals
📎 Source：Kazakhstan Tax Code (published July 2025, effective 2026-01-01, replacing the 2017 law); State Revenue Committee (SRC); China Tax News - New Kazakhstan Tax Code Implementation (2026-07-13)
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