Corporate Income Tax in Kazakhstan

Standard CIT rate — 20%

The standard corporate income tax rate in Kazakhstan is 20% under Tax Code No. 214-VIII, effective 1 January 2026. Sector rates are set out below. CIT is levied on the taxable income of Kazakhstani legal entities and foreign legal entities operating through a permanent establishment in Kazakhstan. Taxable income is calculated as gross income less deductible expenses as defined by the Tax Code.

Sector CIT rates

Agricultural producers pay a reduced rate of 3%. Banks and gambling businesses are subject to a 25% CIT rate (20% for bank income from business lending). Social sector organisations are subject to 5% CIT in 2026, increasing to 10% from 2027. Insurance organisations pay the standard 20% rate.

Investment agreement — 100% CIT reduction

Since 1 January 2026 a Kazakhstani legal entity with an investment agreement under the Entrepreneurial Code No. 375-V may reduce CIT by 100% on income from the investment project in the priority activities named in the agreement, earned through fixed assets commissioned as new, expanded or renewed production (Tax Code, Article 736). The term depends on project value and activity, up to 10 years; for expansion or renewal it is up to 3 years after commissioning. Other income is taxed in the ordinary way, and separate tax accounting is required. New Investment Priority Project contracts are no longer available, but existing contracts keep their CIT reduction until they expire (Tax Code, Article 837). Bond Stone advises on structuring the investment entity within these rules.

AIFC participants — CIT exemption for qualifying services

Participants of the Astana International Financial Centre (AIFC) are exempt from CIT until 1 January 2066 only on income from the financial services listed in Article 6(3) of Constitutional Statute No. 438-V dated 7 December 2015, provided in the AIFC, and on income from legal, audit, accounting and consulting services supplied to AIFC bodies and to those participants (Article 6(4)). AIFC registration alone gives no CIT exemption on other income. Separately, dividends on shares of companies registered under AIFC law, and gains on those shares, are exempt until the same date for all recipients (Article 6(7)), which is why the AIFC is used as a holding jurisdiction. The AIFC RLA status of Bond Stone's partners enables the firm to advise on AIFC participant tax eligibility as part of the overall investment structuring mandate.

CIT deductible expenses — key items

Deductible expenses for CIT purposes include: business expenses incurred in the production of taxable income; depreciation on fixed assets (rates set by the Tax Code); interest on borrowings (subject to thin capitalisation limits on related-party debt); salaries and social contributions; and professional fees. Non-deductible items include: dividends paid to shareholders; penalties and fines; and expenses not supported by proper documentation. Bond Stone advises on the deductibility of specific expense categories in the context of investment structuring mandates.

New Tax Code 2026 — transitional provisions

The new Tax Code No. 214-VIII entered into force on 1 January 2026 — replacing Tax Code No. 120-VI dated 25 December 2017. Existing contracts are protected by the transitional articles of the new Code: Investment Priority Project contracts keep their terms until expiry and investment commitment agreements keep their stability guarantee (Article 837), and agreements on investments concluded before 1 January 2026 keep their tax conditions and stability guarantee until expiry (Article 838). Bond Stone advises on the application of transitional provisions and tax stability guarantees for existing investment contract holders under the new Tax Code framework.