Page 32 - CEE Tax Guide 2025
P. 32

Kyrgyzstan


                           Forvis Mazars LLC
                           118 Moskovskaya st., 5th floor,
                           Business center Olymp, Bishkek,
                           Kyrgyzstan
                           Phone: +996 312 882 155
                           www.forvismazars.com/kg








           Corporate taxes and other direct taxes              VAT and other indirect taxes

           Taxable income is calculated as annual income       The VAT concept is quite similar to the concept
           minus expenses. Only properly documented            applied in developed countries worldwide. Turnover
           expenses may be deducted, provided that expenses    subject to VAT is in general the total value of sales
           are related to the taxable income. Dividends and    (Output VAT). VAT paid to suppliers (input VAT)
           capital gains are excluded from taxable income.     is deducted from Output VAT. Input VAT cannot
           The percentage of depreciation norms for fixed      be offset if the goods, works, or services purchased
           assets is set out in the Tax Code and is substantively   are not related to the taxable turnover, the VAT-
           similar to IFRS principles. Losses can be carried   invoice is not issued by a supplier or is issued
            forward within the following 5 calendar years      in violation of legal requirements, the supplier
            inclusively; the rule on carrying forward losses does   is declared by court as inactive entity, etc. The
           not apply to losses generated during periods when   VAT rate for the export of goods is 0% and there
           a company enjoyed tax benefits. There are no thin   is a procedure for refund of the related input VAT.
           capitalization rules.                               A special VAT procedure applies to the export/import
           WHT is applied to incomes paid to non-residents     of goods to/from the countries belonging to the
           that are not registered for tax purposes            Eurasian Economic Union such as Russia, Belarus,
            in Kyrgyzstan. Taxable incomes are listed in the   Kazakhstan, and Armenia.
           Tax Code. Kyrgyzstan has signed 32 treaties on the   Sales tax applies to revenue besides VAT. The
           avoidance of double taxation. Though the treaty     rate varies from 0% to 5% depending on the type
           rates prevail over the Tax Code, it is important    of activity and whether the revenue was received
           to have a duly issued tax residency certificate for the   in cash or not.
           non-resident to apply the treaty. The multilateral   Excise tax is paid by importers and sellers of:
            instrument (MLI) is not in force.
                                                               1)  Alcoholic products
            Transfer pricing in Kyrgyzstan                     2) Tobacco products

            Arm’s length principle    Since 2009               3) Oil products.
            Documentation liability  No  N/A                    VAT options in Kyrgyzstan  Applicable / limits
            APA                 No    N/A                       Distance selling     No
            Country-by-Country   No   N/A                       Call-off stock       No
            liability
                                                                VAT group registration  No
            Master file-local file   N/A  N/A
            (OECD BEPS 13)                                      Cash accounting – yearly   Available without limits.
            applicable                                          amount in EUR (approx.)
            Penalty                                             Import VAT deferment  No
            lack of documentation     N/A                       Local reverse charge

            tax shortage        N/A   N/A                       Option for taxation
            Related parties     N/A   N/A                       letting of real estate  No

            Safe harbors        20%   N/A                       supply of used real estate  No
            Level of attention paid   8/10                      VAT registration     No
            by Tax Authority                                    threshold

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