Corporate - Significant developments

Last reviewed - 27 December 2019

According to the amendments to the Tax Code introduced by the Kazakhstan government in 2018, the following significant developments became effective in 2019:

  • Temporary and retroactive (from 1 January 2018 till 31 December 2019) exclusion from Kazakh controlled foreign company (CFC) rules for the companies registered in the double tax treaty (DTT) countries with Kazakhstan.
  • Introduction of a so-called ‘horizontal' monitoring format of monitoring (desktop audits) of taxpayers aimed at reduction of the number of field tax audits.
  • Introduction of 3-tier transfer pricing reporting requirements into Kazakhstan Transfer Pricing law (i.e. Country-by-country [CbC] report, Local file, and Master file documentation) as part of the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting (BEPS)-related recommendations.

A draft law on amendments to the Kazakh Tax Code is planned to be reviewed by the Parliament of Kazakhstan in 2020.

Please note that certain amendments would have retrospective effect for the periods 2018 – 2019, which include, among other, amendments with respect to CFC rules, exemption of certain income received by non-residents, increase of land tax rates for unused agricultural land plots, etc.

Once the draft law is approved by the Parliament and signed by the President, WWTS content for Kazakhstan corporate tax would be amended accordingly.