The new Tax Code, coming into effect in Kazakhstan on 1 January 2026, introduces several clarifications and amendments regarding international taxation.
Updated terms and definitions
The legislation now includes clarifications to key definitions:
- Royalties now cover services for updating software versions. However, work related to fixing errors and defects that does not result in the development of the software is not considered royalties and is not subject to taxation.
- The concept of “know-how” and “recruitment services” have been legally defined.
Changes in the taxation of non-resident income
From 2026, services related to information processing, advertising, design, and recruitment will be taxed at 20%, regardless of where they are provided.
The period for recognizing an unfulfilled advance payment is reduced from 2 years to 12 months. If a product or service from a non-resident is not delivered within a year after the advance payment, the amount will be treated as income and subject to taxation.
Changes in rates for dividends and foreign employee salaries
- Dividends: If a non-resident owns 25% or more of a legal entity, income up to 230,000 MCI (904,360,000 KZT in 2025) will be taxed at 5%, and amounts above that – at 15%.
- Salaries: Income up to 8,500 MCI (33,422,000 KZT in 2025) will be taxed at 10%, and amounts above that – at 15%.
- Loan interest: The tax rate is reduced from 15% to 10%.
Additionally, retro bonuses paid when selling goods are now classified as marketing services and are subject to taxation.
What remains unchanged
The principles of international taxation and tax reporting in Kazakhstan remain the same.
Key considerations when working with non-residents
When working with non-residents, it is important to consider:
- whether the country is listed as a preferential jurisdiction;
- whether there is a double taxation avoidance treaty in place;
- where the services are provided – in Kazakhstan or abroad.
For Astana Hub participants, the exemption from taxation on payments of income and royalties to non-residents has been extended until 2029.
