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 rates have been changed:

• CIT rate for banks (except for lending to businesses) and entities providing services of casinos, slot machine halls, totalizators and bookmakers is increased to 25%;
• VAT rate was increased from 12% to 16% and differentiated rates for certain industries are provided;
• A cumulative approach to personal income tax calculation is being introduced. Annual income exceeding 8,500 MCI will be taxed at a rate of 15%;
• 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 (EII) is envisaged via an automated control (for certain taxpayers) and comparative control.

Some 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 G&G pool has been expanded;
• The 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 PE were clarified, in particular, a definition of similar projects was given;
• There is a direct prohibition on application of double tax treaty provisions in case of payment of 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.