Kazakhstan

On 18 July 2025, the President of Kazakhstan signed a new Tax Code introducing the following significant changes entering into force on 1 January 2026:

Tax rate changes

• The corporate income tax (CIT) rate for banks (except for lending to businesses) and entities providing services of casinos, slot machine halls, totalisators, and bookmakers is increased to 25%.

• The value-added tax (VAT) rate is increased from 12% to 16%, and differentiated rates for certain industries are provided.

• The social tax rate has been decreased to 6%, but the amount of social tax is no longer reduced by the amount of social contributions.
• Control over the issuance of electronic invoices is envisaged via an automated control (for certain taxpayers) and comparative control.

Changes for subsoil users

• A definition of the start date of extraction after commercial discovery has been added.
• Previously, the global oil price was determined using only Urals and Brent oil price quotations. The quotation for ’Kazakh Export Blend Crude Oil‘ (KEBCO, Kazakh oil) has been added.
• The list of expenditures to be included in the geological and geophysical (G&G) pool has been expanded.
• The mineral extraction tax (MET) rates for gold and silver will be determined based on the exchange price. A progressive taxation scale linked to market dynamics has been introduced (i.e. the higher the gold price, the higher the tax rate).

Changes in international taxation

• The criteria for creating a permanent establishment (PE) were clarified; in particular, a definition of similar projects was given.
• There is a direct prohibition on application of double tax treaty (DTT) provisions in case of payment of withholding tax (WHT) by a tax agent at its own expense.
• A general 5% WHT rate is introduced when distributing dividends to a non-resident holding at least 25% of the capital of a resident paying dividends; at the same time, the 10% WHT on dividends under the ’three-year‘ incentive is eliminated.
• The ’three-year‘ incentive related to capital gains from sale of shares / stock is eliminated.
• A 10% tax rate is established in relation to interest on loans (borrowings) and debt securities paid to a non-resident.
• The capital gain tax exemption from the sale of securities by open trading on the Kazakhstan Stock Exchange has been retained only for non-resident individuals.
• The procedure for the application of an international treaty by a tax agent is amended; in particular, the condition for mandatory taxation of income in the related non-resident's country at minimum 15% is eliminated.