FOREIGN INVESTMENT  ·  KAZAKHSTAN

Investment Incentives & SEZs in Kazakhstan

Bond Stone advises foreign investors on investment incentives in Kazakhstan — Special Economic Zones (SEZs), investment agreements and other investment contracts, the Astana Hub (IT sector), and sector-specific tax incentives under the Tax Code and Entrepreneurial Code. SEZ participation can reduce corporate income tax, land tax and property tax on qualifying priority activities, on the conditions in the Tax Code.

Primary authority: Law of the Republic of Kazakhstan on Special Economic and Industrial Zones No. 242-VI dated 3 April 2019; Entrepreneurial Code of the Republic of Kazakhstan No. 375-V dated 29 October 2015, Chapter 25 (investment contracts); Tax Code of the Republic of Kazakhstan No. 214-VIII dated 18 July 2025 (entered into force 1 January 2026, replacing Tax Code No. 120-VI dated 25 December 2017), Articles 17, 734–738. Authority: adilet.zan.kz


Key Framework

Special Economic Zones — framework

Kazakhstan's SEZ framework is governed by the Law on Special Economic and Industrial Zones No. 242-VI dated 3 April 2019. According to the Ministry of Industry and Construction, 18 SEZs were operating in October 2026, four of them created in 2025–2026: Aktobe, Korkyt Ata, Atyrau and Industrial Trade and Logistics Complex Alatau. All 18 are listed in Special Economic Zones in Kazakhstan, and the two zones at the Chinese border are covered in Khorgos Eastern Gate SEZ. Each SEZ has its own priority activities and operating conditions. For priority activities, SEZ participants benefit from: a 100% reduction of corporate income tax (CIT); land tax and property tax relief; and the free customs zone procedure for imported goods. For participation contracts concluded after 1 January 2024 the tax relief runs for 7, 15 or 25 years under project-value categories A, B and C (Tax Code, Article 735). Goods supplied into an SEZ and fully consumed in activities meeting its purposes are zero-rated for VAT (Tax Code, Article 470); otherwise SEZ participants follow the general VAT rules, with specific exemptions.

Investment agreements

New Investment Priority Project contracts are no longer available: since 1 January 2026 tax preferences are granted through an investment agreement under Article 283-1 of the Entrepreneurial Code. It can offer a 100% CIT reduction, a land tax coefficient of 0, property tax at 0%, state in-kind grants and the right to engage foreign workers. The tax preferences run for up to 10 years, depending on project value and activity (Tax Code, Article 736). New production requires a minimum investment of 2 million MCI (approximately USD 17 million at current rates), and expansion or renewal 5 million MCI, in a priority activity approved by the Government. Existing Investment Priority Project contracts continue until they expire (Tax Code, Article 837). Bond Stone advises on qualification and the application process with the authorised investment body.

Astana Hub — IT sector

The Astana Hub is an innovation cluster for IT companies, not a Special Economic Zone: its participants are excluded from the SEZ tax regime (Tax Code, Article 734). A company registered with the Astana Hub autonomous cluster fund that earns at least 90% of its annual income from priority ICT activities may apply a 100% CIT reduction, VAT exemptions and social tax relief (Tax Code, Articles 17 and 738). These rules apply until 1 January 2029 (Tax Code, Article 848). Foreign managers and specialists with higher education working at the Astana Hub or its participants are outside the quota and employer work permit rules (Law on Population Migration No. 477-IV, Art. 36-1(2)). Bond Stone advises on Astana Hub residency eligibility and registration.

Investment contracts — stability guarantees

Stability terms depend on the contract. An investment agreement fixes the agreed tax coefficients, rates and reductions until its tax preferences end, up to 10 years (Tax Code, Article 736). An investment commitment agreement with the Government gives a 10-year guarantee of tax stability, with exceptions such as VAT and excise (Tax Code, Article 737). Agreements on investments concluded before 1 January 2026 keep their tax conditions and stability guarantee until they expire (Tax Code, Article 838). Bond Stone advises on qualifying for and negotiating investment contracts with the relevant Kazakhstani state authority.

Tax treaties — double taxation relief

Kazakhstan has double taxation treaties (DTTs) with many states (55 in force on the State Revenue Committee's list of 28 April 2023) — including China, Germany, the Netherlands, UAE, UK, and USA. DTTs can reduce withholding tax on dividends, interest, and royalties paid to foreign investors. Under Kazakhstani domestic law, withholding tax on dividends is 15%, or 5% on dividends up to 230,000 MCI for a shareholder holding at least 25% directly or indirectly (Tax Code, Article 682). Treaty rates vary, and many treaties allow 5% for qualifying corporate shareholders. Bond Stone advises on DTT eligibility analysis as part of every investment structuring mandate.


Experience

Bond Stone has advised foreign investors on investment structuring in Kazakhstan since 2007. Client confidentiality is maintained across all matters.

Incentives · Kazakhstan · SEZ · China

SEZ Application — Chinese Manufacturer

Advising a Chinese manufacturer on SEZ residency in Kazakhstan — eligibility assessment against qualifying activity requirements, minimum investment threshold analysis, application preparation, and review of SEZ operating conditions and tax incentive schedule.

Incentives · Kazakhstan · Energy

Investment Incentive Eligibility — Energy Sector

Advising a foreign energy investor on investment incentive eligibility — investment threshold analysis, priority sector confirmation, application with the Ministry, and negotiation of investment contract with stability guarantee.

Incentives · Kazakhstan · Technology

Astana Hub Registration — IT Company

Advising a foreign IT company on registration as an Astana Hub resident — eligibility assessment, application preparation, income tax and VAT exemption confirmation, and work permit advisory for foreign IT specialists.

Incentives · Kazakhstan · Tax

DTT Analysis — Dividend Repatriation

Advising a foreign investor on applicable double taxation treaty rates for dividend repatriation from Kazakhstan — beneficial ownership analysis, treaty eligibility confirmation, and withholding tax optimisation.

Incentives · Kazakhstan · SEZ

SEZ Compliance — Operating Conditions

Advising a manufacturing company on compliance with SEZ operating conditions — qualifying activity monitoring, minimum investment fulfilment, annual compliance reporting, and assessment of risk of SEZ status revocation.

Incentives · Kazakhstan · Corporate

Investment Contract — Stability Guarantee

Advising a European investor on qualifying for and negotiating an investment contract with the government of Kazakhstan — investment incentive eligibility, investment threshold confirmation, and stability guarantee scope negotiation.

Why Bond Stone

Primary authority: adilet.zan.kz


Discuss your Kazakhstan investment

Contact Bond Stone for a confidential discussion about Investment Incentives & SEZs in Kazakhstan.

info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty

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