Page 28 - CEE Tax Guide 2025

Kazakhstan
Forvis Mazars LLP
34, Abish Kekilbaiuly st, Business
center Capital TowerAlmaty,
Kazakhstan
Phone: +7 778 873 7159
www.forvismazars.com
Corporate taxes and other direct taxes
In general, the concept resembles the CIT concept
applied in developed countries worldwide. Taxable
income is calculated as annual income minus
expenses. It is possible to deduct expenses linked
to incomes recognized for CIT purposes, provided
that such expenses are properly documented.
Dividends and capital gains are not excluded
Transfer pricing in Kazakhstan
Arm’s length principle Since 2009
Documentation liability Since 2009
APA Since 2009
Country-by-Country Since 2016
liability
Master file-local file Since 2019
(OECD BEPS 13)
applicable
Penalty
lack of documentation N/A From EUR 740
to EUR 7,400
tax shortage N/A From 20% up to 300%
of tax shortage.
Related parties N/A TP rules apply to all
cross-border transactions
even if the parties are
unrelated. The transfer
pricing law defines related
parties as individuals
or legal entities whose
special mutual relations
may allow the economic
results of the transactions
to be influenced.
In consequence, the
Kazakh authorities can
treat any transaction
as a transaction
between related parties
based on their set
of market prices.
Safe harbors N/A A 10% deviation is allowed
only for producers
of agricultural products. VAT cannot be offset if goods, works, and services
Level of attention paid 8/10
by Tax Authority
Central and Eastern European tax guide 2025
from taxable income by default, it is necessary
to analyze who is the beneficiary etc. to identify
the applicable taxation regime. There are certain
limits on deductibility of expenses such as: up to 3%
of taxable profit for certain fees paid to companies
from offshore jurisdictions, up to 4% of taxable profit
for sponsorship fees. Also, thin capitalization rule
is applied to interest on related party loans. The list
is not exhaustive. Depreciation expenses on fixed
assets differ from IFRS principles and are calculated
on a group basis based on tax book value as of the
reporting date. Loss carry-forward can be done
within the following 10 calendar years inclusively, the
rule on the carrying forward of losses does not apply
to losses generated from the sale of securities, etc.
There are Controlled Foreign Company rules (CFCs).
WHT applies to incomes paid to non-residents who
are not registered for tax purposes in Kazakhstan.
Taxable incomes are listed in the Tax Code.
Kazakhstan has signed 55 treaties on the avoidance
of double taxation. The treaty rates prevail over the
Tax Code; however, any non-residents are required
to have a duly issued tax residency certificate
in order to apply the treaty. The multilateral
instrument (MLI) entered into force in Kazakhstan
from October 2020; however, it is important
to check the MLI accession documents signed
with each country as some of them have not
signed/ratified the MLI or have done so under
certain conditions.
Small and medium businesses may enjoy a special
tax regime, according to which the Unified Tax
on income is paid. Such tax replaces CIT.
VAT and other indirect taxes
The VAT concept is quite similar to the concept
applied in developed countries worldwide. The VAT
applicable to turnover is in general based on the total
value of sales (Output VAT). VAT payable to suppliers
(input VAT) is offset against from Output VAT. Input
purchased are not related to taxable turnover, a VAT-
invoice is not issued by a supplier or is issued with
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