Astana Hub in 2026: New Participation Rules, the Auditor-Confirmed Report and the New Counter-Obligations

From 23 January 2026 the activity of Astana Hub participants is governed by new Rules approved by Order No. 703/НҚ of 31 December 2025, and since July 2026 by an amended version of those Rules. The Rules replaced a 2018 order that had stood for seven years and introduced two genuinely new duties: an annual report on the structure of income, the data in which is confirmed by an auditor, and counter-obligations to develop the IT ecosystem. At the same time the tax reliefs moved into a new Tax Code — Code No. 214-VIII of 18 July 2025, in force from 1 January 2026.

⚠️ Three features change the picture and are almost nowhere reflected. One: the “mandatory audit” in its original form lasted less than seven months. Paragraph 33 of the Rules as adopted on 31 December 2025 required participants with annual income above KZT 100,000,000 to “conduct an audit” by 1 July. Order No. 421/НҚ of 17 July 2026 restated the paragraph: it is now a report and/or conclusion whose data is confirmed by an auditor, for income above 30,000 MCI, due by 20 July. Everything published in the first half of 2026 describes the superseded text. The new text, however, took effect after both reporting dates, so the 2026 cycle ran on the old rule and the new construction applies for the first time in 2027. Two: the biggest change of 2026 is not the audit but paragraph 31-1. The same July order added counter-obligations to develop the IT ecosystem, the volume of which is set by the Fund’s internal documents. Failing them is a standalone ground for early termination of participation under paragraph 28(7). Three: article 13-1 of the Law “On Informatization” no longer exists. It was excluded by Law No. 220-VIII of 27 September 2025. The framing statute is now Law No. 207-V of 10 June 2014, retitled by the same law as “On the Innovation Cluster ‘Astana Hub’”. A citation to article 13-1 today is a citation to a repealed provision.

This analysis states the position as at August 2026 and describes only instruments in force.

The Legal Framework: Four Layers and One Repealed Article

The Astana Hub regime rests on one statute, three ministerial orders and one chapter of the Tax Code, and the layers must be kept apart because they change at different speeds.

Layer 1 — the framing statute. Law of the Republic of Kazakhstan No. 207-V of 10 June 2014 “On the Innovation Cluster ‘Astana Hub’”. The title of the law was restated by Law No. 220-VIII of 27 September 2025; the previous title referred to the “Park of Innovative Technologies”. The same law added subparagraph 2-1) to article 7, bringing Astana Hub participants within the participants of the innovation cluster, and added article 7-1 on foreign labour.

A terminological shift in 2026 is worth noting separately. Law No. 256-VIII of 9 January 2026 replaced, throughout Law No. 207-V, the words “information and communication technologies”, “in the field of informatization” and “information, communication and innovative technologies” with “digital technologies”, “in the field of digitalisation” and “digital and innovative technologies” respectively; the replacement takes effect six months after the day of the law’s first official publication. The Tax Code retained the older terminology — “information and communication technologies”. The divergence is formal, but it matters when citing the instruments precisely.

What has ceased to apply. Law No. 220-VIII excluded from Law No. 418-V of 24 November 2015 “On Informatization”subparagraphs 33-1), 33-2) and 55-2) of article 1, subparagraphs 24-1) and 59-1) of article 7, and article 13-1 “International Technology Park ‘Astana Hub’” in its entirety. The words “technopark” and “IT startup” no longer appear anywhere in the Law on Informatization as in force.

Layer 2 — the rules of activity. Order of the Deputy Prime Minister — Minister of Artificial Intelligence and Digital Development No. 703/НҚ of 31 December 2025 “On Approval of the Rules of Activity of the Autonomous Cluster Fund ‘Astana Hub’”, registered with the Ministry of Justice on 5 January 2026 under No. 37807. It was issued “in accordance with subparagraph 4) of paragraph 4 of article 9 of the Law of the Republic of Kazakhstan ‘On the Innovation Cluster Astana Hub’”. Amended by Order of the acting Minister of Artificial Intelligence and Digital Development No. 421/НҚ of 17 July 2026, registered with the Ministry of Justice on 20 July 2026 under No. 39352. The same order restated Annexes 1 and 2 to the Rules and deleted Annex 3, thereby replacing the business plan template itself.

Layer 3 — the list of priority activities. Order No. 521/НҚ of 20 October 2025, registered with the Ministry of Justice on 21 October 2025 under No. 37182, in force from 1 January 2026. Issued “in accordance with paragraph 2 of article 17 of the Tax Code”.

Layer 4 — the tax layer. Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025 “On Taxes and Other Obligatory Payments to the Budget (Tax Code)”, in force from 1 January 2026. The reliefs sit in Chapter 82 of Section 17 (articles 738 to 741), and the definition of a participant sits in article 17. The 2017 Tax Code ceased to have effect on the day Code No. 214-VIII came into force — subparagraph 1) of paragraph 3 of article 848.

Layer 5 — confirming entitlement to the CIT relief. Order No. 599/НҚ of 27 November 2025, registered with the Ministry of Justice on 28 November 2025 under No. 37492, in force from 1 January 2026, issued under paragraph 2 of article 741 of the Tax Code.

Instrument	Number and date	Ministry of Justice registration	In force from
Law “On the Innovation Cluster ‘Astana Hub’”	No. 207-V of 10.06.2014	—	title as restated by Law No. 220-VIII of 27.09.2025
Rules of activity of the Fund	No. 703/НҚ of 31.12.2025	No. 37807 of 05.01.2026	23 January 2026, except subparagraphs 8) and 9) of paragraph 7
Amendments to the Rules	No. 421/НҚ of 17.07.2026	No. 39352 of 20.07.2026	ten calendar days after first official publication — no earlier than the beginning of August 2026
List of priority activities	No. 521/НҚ of 20.10.2025	No. 37182 of 21.10.2025	1 January 2026
Rules confirming entitlement to the CIT reduction	No. 599/НҚ of 27.11.2025	No. 37492 of 28.11.2025	1 January 2026
Tax Code	No. 214-VIII of 18.07.2025	—	1 January 2026

A note on source access. The official legal portal adilet.zan.kz is closed to automated retrieval. Every provision of the Rules, the Tax Code, Law No. 207-V, the Social Code and the compulsory medical insurance law cited here has been checked against consolidated texts on the mirrors zakon.uchet.kz, pavlodar.com, zakon.mybuh.kz and kodeksy-kz.com; the mirror is named for each group of citations in the source list. Order No. 421/НҚ of 17 July 2026 was registered with the Ministry of Justice of the Republic of Kazakhstan on 20 July 2026 under No. 39352 — the details were checked against the consolidated text of the order itself on the zakon.uchet.kz mirror. The date of first official publication is not reproduced on that mirror; the mirrors put it at 24 July 2026, which gives an entry into force of 4 August 2026.

Who Is an Astana Hub Participant — and Why There Are Two Definitions

Astana Hub is an autonomous cluster fund, and an Astana Hub participant is a legal entity registered by that Fund as a participant. There are two definitions of “participant” and they do not coincide: one governs admission to the register, the other governs the tax reliefs.

The admission definition — paragraph 7 of the Rules approved by Order No. 703/НҚ. Ten conditions an applicant must satisfy for the Selection Commission to register it. These are entry conditions.

The tax definition — article 17 of the Tax Code. A legal entity is an Astana Hub participant if it simultaneouslysatisfies three conditions:

•          1) it is registered with the autonomous cluster fund “Astana Hub” as a participant in accordance with Kazakhstan’s innovation cluster legislation;

•          2) not less than 90 per cent of its aggregate annual income consists of income from priority activities in the field of information and communication technologies;

•          3) where goods are produced and sold, those goods meet the own-production criteria.

The gap between the two definitions is where the most expensive mistake in this regime lives. Registration in the Fund’s register confers participant status but does not by itself confer the tax reliefs. Entitlement arises only if the 90 per cent threshold in article 17 of the Tax Code is also met. A participant whose core-activity share slips to 85 per cent stays on the register — and loses the relief.

What else counts towards the 90 per cent. The second part of paragraph 1 of article 17 expressly lists four categories that count towards the subparagraph 2) figure provided they are connected with earning income from priority activities:

•          income in the form of property received free of charge;

•          remuneration on deposits;

•          the excess of positive foreign exchange differences over negative ones;

•          income from doubtful liabilities, including penalties and fines on such liabilities.

The foreign exchange item is the most practically significant of the four. An export-oriented IT company with foreign currency revenue realises exchange differences continuously, and without this provision they would dilute the denominator and push the company towards the 90 per cent boundary.

Who approves the list of priority activities — paragraph 2 of article 17. The list and the own-production criteria are approved by the authorised body in the field of informatization in agreement with the central authorised body for state planning, the authorised body for technical regulation, the authorised body for state support of innovation activity, and the authorised body. In other words the list is an instrument agreed by four government bodies, not the decision of a single ministry.

Where a participant sits within the innovation cluster. Subparagraph 2-1) of paragraph 2 of article 7 of Law No. 207-V, added by Law No. 220-VIII of 27 September 2025, places Astana Hub participants among the participants of the innovation cluster alongside participants of the “Park of Innovative Technologies” special economic zone and legal entities holding the status of research organisations, technoparks, education organisations and development institutions.

Governing bodies of the Fund — article 9 of Law No. 207-V. The supreme body is the Managing Committee, chaired by the head of the authorised body in the field of digitalisation. Its exclusive competence includes, among other things, “determining the audit organisation carrying out the external audit of the Fund” — subparagraph 4) of paragraph 2 of article 9.

Do not conflate two different audits. The external audit of the Fund itself is carried out by an audit organisation determined by the Managing Committee under article 9(2)(4) of the Law. The participant’s report under paragraph 33 of the Rules is an entirely different document, with a different subject matter, a different client and a different recipient. The coincidence of the word “audit” in both contexts accounts for much of the confusion around the new rules.

The authorised body has changed and is now named differently. The 2018 Rules were approved by the Minister of Information and Communications; subsequent amendments came from the Ministry of Digital Development, Innovation and Aerospace Industry. The Rules in force were approved by the Deputy Prime Minister — Minister of Artificial Intelligence and Digital Development of the Republic of Kazakhstan, with the Committee for Digital Assets and Breakthrough Technologies named as the responsible unit.

The broader choice of legal form in Kazakhstan — an LLP against a branch of a foreign company — is analysed in Branch and Representative Office of a Foreign Company vs an LLP in Kazakhstan in 2026.

What Actually Changed: the 2026 Rules Against the 2018 Order

Order No. 703/НҚ of 31 December 2025 replaced five earlier orders and came into force on 23 January 2026 — ten calendar days after its first official publication.

The list of repealed instruments is set out in the annex to Order No. 703/НҚ:

No.	Repealed instrument	MoJ registration
1	Order of the Minister of Information and Commu­nica­tions of 26.09.2018 No. 415 “On Approval of the Rules of Activity of the International Technology Park ‘Astana Hub’”	No. 17437
2	Order of the Ministry of Digital Development of 12.08.2021 No. 277/НҚ	No. 23981
3	Order of the acting Minister of Digital Development of 23.08.2022 No. 292/НҚ	No. 29243
4	Order of the Ministry of Digital Development of 26.01.2023 No. 29/НҚ	No. 31817
5	Order of the Ministry of Digital Development of 04.08.2023 No. 317/НҚ	No. 33255

Paragraph 5 of Order No. 703/НҚ carries a deferred limb, and it is a significant one. Verbatim: “This order comes into force ten calendar days after the day of its first official publication, with the exception of subparagraphs 8) and 9) of paragraph 7 of the Rules, which come into force from 1 January 2029.”

The two harshest admission conditions do not operate until 2029, and this is almost never reported. What is deferred is precisely the requirement that activity be oriented predominantly towards export and the cap of 50 per cent on income from contracts with state bodies and quasi-state sector entities. Until 1 January 2029 an applicant need not be an exporter and may work predominantly on public contracts. From 1 January 2029 both constraints switch on — on the very date the tax reliefs themselves expire.

The July 2026 amendments touched at least twelve paragraphs of the Rules. Order No. 421/НҚ of 17 July 2026restated or amended paragraphs 6, 7, 12, 18, 24, 25, 26, 30, 32, 33 and 40, the heading of paragraph 2 of Chapter 3, and added paragraph 31-1.

Key parameters before and after July 2026:

Parameter	Text of 31.12.2025	Text after Order No. 421/НҚ
Threshold for the annual report	annual income above KZT 100,000,000	annual income above 30,000 MCI
Filing deadline	annually by 1 July	annually by 20 July
Nature of the document	“conduct an audit”	“submit a report and/or conclusion” whose data is confirmed by an auditor
Counter-obligations to develop the IT ecosystem	none	introduced by paragraph 31-1
Term of participation	determined by the Fund	determined by the Fund and not less than 1 year
Ground of termination for “failure to submit information and reports”	unspecified	tied to paragraphs 37, 38 and 39 of the Rules
Ground of “prohibited activity”	on establishment of the fact	requires a court act that has entered into force

The threshold converted into tenge. The monthly calculation index for 2026 is KZT 4,325, set from 1 January 2026 by subparagraph 4) of article 7 of the Law of the Republic of Kazakhstan No. 239-VIII of 8 December 2025 “On the Republican Budget for 2026–2028”. The MCI was not revised during 2026, so a single figure applies for the whole year. Accordingly 30,000 MCI equals KZT 129,750,000 in 2026.

The threshold was not lowered — it was raised, and indexed. Replacing a fixed KZT 100,000,000 with 30,000 MCI lifted the bar by KZT 29,750,000 in 2026 and simultaneously freed the provision from annual revision: as the MCI rises, the threshold will rise with it. Author’s assessment: this is neither a tightening nor a relaxation in principle but a conversion to indexation — although in 2026 the effect on taxpayers is unambiguously favourable.

The requirement of a court act is the second relaxation. Under the previous text the mere “establishment of the fact” of prohibited activity was a ground for early termination. Subparagraph 8) of paragraph 28 now requires the fact to be “confirmed by a court act that has entered into force”. Author’s assessment: this is a meaningful procedural safeguard — the Fund can no longer terminate participation on its own legal assessment of what a participant is doing.

The chronology settles which rule applied in 2026, and the answer is unambiguous. Order No. 421/НҚ is dated 17 July 2026, was registered with the Ministry of Justice on 20 July 2026 under No. 39352, and comes into force ten calendar days after the day of first official publication. Publication follows registration, so the order cannot have taken effect before the beginning of August 2026 — that is, after both reporting dates: the old one (1 July) and the new one (20 July).

The practical conclusion: the 2026 reporting cycle ran on the original text of paragraph 33. Participants with annual income above KZT 100,000,000 were required by 1 July 2026 to conduct an audit and submit an auditor’s report to the Fund. The new construction — a report and/or conclusion for income above 30,000 MCI by 20 July — applies for the first time to the 2027 cycle. This also explains why Astana Hub’s own notice of 22 January 2026, and the commentary published in spring 2026, describe an audit: at that time an audit was the rule in force.

The original paragraph 33, verbatim, for comparison:

“Astana Hub participants with annual income exceeding KZT 100,000,000 (one hundred million) shall, annually, by 1 July, conduct an audit confirming the compliance of their activity with the requirements of the List of priority ICT activities and with the income structure, and submit the auditor’s report to the Fund.”

Order No. 421/НҚ changed more than the text of the Rules. It restated Annex 1 (the information to be described in the project business plan) and Annex 2 (the form of the participant’s certificate of registration), and deleted Annex 3. The order was signed by the acting Minister and agreed with the Ministry of Finance and the Ministry of Industry and Construction.

One detail shows the character of the July amendments. The original paragraph 24 provided that the term of participation “may not be not less than 1 (one) year” — a self-contradictory formulation. Order No. 421/НҚ replaced it with “may not be less than 1 (one) year”. Author’s assessment: part of the July package is repair of defects in the December text rather than a change of policy, and the two need to be told apart when reading the “as restated by order” footnotes.

The Ten Admission Conditions: Who Astana Hub Will Not Take

To be registered as a participant an applicant must satisfy all ten requirements of paragraph 7 of the Rules simultaneously — but two of them do not operate until 1 January 2029.

No.	Requirement under paragraph 7 of the Rules	In force from
1)	Be a legal entity	23.01.2026
2)	Have no branches at the date the application is filed	23.01.2026
3)	Not be an organisation implementing (or having implemented) an investment priority projectunder article 284 of the Entre­preneu­rial Code, or an investment strategic project under contracts concluded before 1 January 2015	23.01.2026
4)	Not be a legal entity 50 per cent or more of whose shares or participation interests belong to the State, national holdings, national companies or their subsidiaries	23.01.2026
5)	Not be a subsoil user or a participant of a special economic zone	23.01.2026
6)	Not be an excise payer under article 535 of the Tax Code	23.01.2026
6-1)	Not implement projects aimed at the promotion, marketing or increase in sales of goods listed in subparagraphs 2), 3), 4) and 9) of article 536 of the Tax Code	23.01.2026
7)	Carry on one or more priority ICT activities under the List approved by Order No. 521/НҚ	23.01.2026
8)	Carry on activity oriented predominantly towards the export of goods, works and services outside the Republic of Kazakhstan	1 January 2029
9)	Income under contracts with state bodies and quasi-state sector entities not exceeding 50 per centof aggregate annual income	1 January 2029
10)	The project’s goods, works and services must not be directed at promoting or servicing gambling, financial (investment) pyramids or any other activity prohibited by law	23.01.2026

The no-branches requirement in subparagraph 2) is tested only at the moment of application. The wording is “the absence, at the moment the application is filed for registration as an Astana Hub participant, of branches”. Author’s assessment: read literally, this does not prohibit opening a branch after registration; but the Rules contain no express permission either, and a regional structure should be cleared with the Fund in advance.

Mutual incompatibility with three other regimes. Subparagraphs 3), 4) and 5) build three exclusions at once: no investment priority or strategic project, no subsoil use, no special economic zone participation. Law No. 215-VIII of 18 July 2025 additionally inserted an exclusion for Astana Hub participants into subparagraph 3) of paragraph 4 of article 283-1 of the Entrepreneurial Code — so Astana Hub membership and investment preferences are mutually exclusive from both directions.

Subparagraph 6-1) is a new anti-circumvention rule. It closes the structure in which a participant formally develops software while in substance servicing the promotion of excisable goods through an IT platform. The cross-reference runs to subparagraphs 2), 3), 4) and 9) of article 536 of the Tax Code — to specific items in the excisable goods list, not to the whole list.

Subparagraph 10) excludes gambling and pyramids, and it is the only condition where the Rules name a prohibited activity expressly. The wording covers not only gambling itself but “promotion or servicing” of activity in that field — that is, the development of platforms and supporting services for operators.

The export-orientation requirement is the most serious of the deferred conditions, and preparation for it should start now. The wording of subparagraph 8) — activity “oriented predominantly towards export” — contains no numerical threshold. Neither the Rules nor the Tax Code defines what share of export is predominant or how it is measured. Until 1 January 2029 the uncertainty is harmless. After that it becomes a matter for the Selection Commission’s judgement, and a participant with predominantly Kazakh revenue should be planning its sales structure today.

What accompanies the application. The application is filed electronically on the Fund’s web resource with the documents listed in paragraph 9 of the Rules, including a business plan whose content must match Annex 1 to the Rules. The application may be completed in Kazakh, Russian or English; where English is used the Fund arranges translation into Kazakh or Russian. Paragraph 11 places responsibility for the completeness and accuracy of the documents, source data, calculations and justifications on the applicant.

How Registration Works: Timelines, the Commission and Grounds for Refusal

The decision to register is taken neither by the Fund nor by the ministry, but by the Astana Hub Selection Commission, whose regulations and composition are determined by the Fund itself.

The full timetable under paragraphs 8 to 19 of the Rules:

Stage	Who	Time limit	Provision
Filing the electronic application with a business plan	Applicant	—	paras 8, 9
Review for completeness, accuracy and compliance with requirements	Fund	15 working days	para 12
Notification of defects where the application is incomplete or inaccurate	Fund	5 working days	para 14
Referral to the Commission once defects are remedied	Fund	on remedy	para 15
Consideration and decision to register or refuse	Commission	10 working days	para 15
Notification of registration or reasoned refusal	Fund	5 working days from the Commission’s decision	para 17
Issue of the electronic certificate	Fund	3 working days from signature of the standard contract	para 18
Inclusion in the List of Participants on the Fund’s website	Fund	3 working days from signature of the standard contract	para 19

The composition of the Commission is set by paragraph 13. It comprises representatives of state bodies and/or appropriately qualified ICT specialists, and international experts may also be brought in. The Commission’s regulations and composition are determined by the Fund — they are not approved by ministerial order.

There are exactly two grounds for refusal — paragraph 16 of the Rules:

•          non-compliance of the business plan with the content required by Annex 1 to the Rules;

•          non-correspondence of the applicant’s project with one or more of the priority ICT activities, or with one or more of the works specified within a given priority activity.

The list of refusal grounds is closed, and that works in the applicant’s favour. The Commission may not refuse on grounds of expediency, team quality, investment volume or market prospects. Refusal is possible only for formal non-compliance of the business plan with Annex 1, or for non-correspondence of the project with the List of priority activities. Paragraph 17 provides expressly: “Rejection of the application does not prevent a repeat application by the applicant, provided the reasons for rejection are remedied.”

The certificate and the register entry are tied not to the Commission’s decision but to signature of the standard contract. Paragraphs 18 and 19, as restated by Order No. 421/НҚ, run their three-day periods from the day the standard contract on the conditions of activity of an Astana Hub participant is signed. The certificate is issued in the form of Annex 2 to the Rules, electronically.

Term of participation — paragraph 24 as restated. The term is determined by the Fund and may not be less than one year. No upper limit is set by the Rules. An application to extend is filed not later than 10 working days before the term expires (paragraph 25); on extension the Fund amends the certificate.

Changing or adding an activity — paragraph 20. The participant files an electronic application with a business plan attached, and the decision is taken by the Commission within 10 working days. This is a practical point of substance: expanding the product line beyond the declared activity is not an internal matter for the company — it requires a separate Commission decision.

Membership fees — paragraphs 21 to 23. A participant pays membership fees to the Fund on income received in the preceding quarter, not later than the 25th day of the month following the expired quarter. Fees are credited to the Fund’s current account with a second-tier bank in Kazakhstan. The amount of the membership fee is determined by an internal normative document of the Fund — the Rules do not set it.

> Author’s assessment: the membership fee is the only material parameter of the regime placed entirely outside the normative act. It is not published in the Rules, is not agreed with the ministry, and can be changed by the Fund’s own decision. It should be requested from the Fund before an application is filed rather than after registration — and it should be remembered that non-payment is a standalone ground for early termination of participation under subparagraph 6) of paragraph 28.

The Mandatory Audit: What Paragraph 33 Actually Requires

Astana Hub participants are not subject to a mandatory audit of their financial statements. Paragraph 33 of the Rules requires a report and/or conclusion on the structure of income and the compliance of activity with the List of priority activities, the data in which is confirmed by an auditor.

Paragraph 33 as in force — restated by Order No. 421/НҚ of 17 July 2026 — verbatim:

“Astana Hub participants with annual income exceeding thirty-thousand times the monthly calculation index shall, annually, by 20 July, submit a report and/or conclusion on the structure of income and the compliance of activity with the requirements of the List of priority ICT activities. The information stated in the report and/or conclusion is confirmed by an auditor in accordance with the Law of the Republic of Kazakhstan ‘On Auditing Activity’.”

The provision broken down:

Element	Content	Comment
Who is caught	Participants with annual income above 30,000 MCI	In 2026 that is above KZT 129,750,000 at an MCI of KZT 4,325
What is submitted	A report and/or conclusion	Not an audit opinion on financial statements
On what	The structure of income and the compliance of activitywith the List of priority ICT activities	Two subjects, both tied to article 17 of the Tax Code
Who confirms	An auditor under the Law “On Auditing Activity”	It is the information that is confirmed, not the accounts as a whole
When	Annually by 20 July	Previously 1 July
To whom	The Fund	Not stated expressly in paragraph 33; it follows from the scheme of the Rules

The decisive difference from an audit of financial statements is the subject matter. An audit of financial statements answers whether the accounts fairly present the company’s financial position. Paragraph 33 answers two different questions: what the structure of income is, and whether the activity corresponds to the List of priority activities. Those are precisely the two questions on which satisfaction of the 90 per cent threshold in article 17(1)(2) of the Tax Code depends.

What paragraph 33 does not contain matters as much as what it does.

No engagement standard is specified. The Rules refer only to the Law “On Auditing Activity” and do not state whether the work is performed as an audit, a review or an agreed-upon-procedures engagement. The form of the deliverable is therefore a matter for the engagement letter with the audit firm, not a prescription of the normative act.

No allocation of cost is specified. The obligation falls on the participant, from which it follows that the participant bears the cost; but the Rules contain no express provision.

No sanction is specified. The Rules attach no particular consequence to failure to submit the paragraph 33 report.

And here lies the most underappreciated feature of the design. Subparagraph 4) of paragraph 28 of the Rules names “failure to submit information and reports” as a ground for early termination — but it expressly confines that to paragraphs 37, 38 and 39 of the Rules, that is, to the monitoring reports. Paragraph 33 is not among them. Failure to submit the annual report on the structure of income is therefore formally not a standalone ground for removal from the participant list. An important qualification: this restriction did not appear in July 2026 — it was already present in the original Rules of 31 December 2025, where paragraph 28 had seven subparagraphs. Order No. 421/НҚ added an eighth and rewrote the seventh to reference the new paragraph 31-1, but left the “37, 38 and 39” list untouched. Author’s assessment: the gap should not be relied on as protection — the same omission remains evidence of non-compliance with article 17 of the Tax Code on a tax audit, with consequences considerably more expensive than removal from the register.

How the paragraph 33 report relates to the tax relief. There is no direct legal link between paragraph 33 of the Rules and Chapter 82 of the Tax Code: paragraph 33 is an obligation owed to the Fund, while entitlement to the relief is governed by article 17 of the Tax Code and confirmed through the separate procedure under Order No. 599/НҚ. In practice, however, the paragraph 33 report is the only document in which a participant records annually the structure of its income by priority activity, and it becomes the primary evidence that the 90 per cent threshold was met if the question ever arises.

“Auditor” is not any professional. The Law “On Auditing Activity” imposes requirements on auditors and audit organisations, including compulsory membership of a professional body. Confirmation by an accountant, a tax adviser or an internal control function does not satisfy paragraph 33.

Separately from paragraph 33, paragraph 32 imposes a disclosure-on-demand duty. As restated by the same Order No. 421/НҚ, a participant must within 10 working days of the Fund’s request provide information required for tax accounting purposes and information from its accounting (financial) statements; and within the same period, copies of state statistical reporting and of tax returns (calculations) for the taxes, fees and duties it pays. The Fund thereby acquires the right to obtain a participant’s tax returns directly, bypassing the tax authority.

Counter-Obligations: the Change of 2026 Almost Nobody Is Writing About

Paragraph 31-1 of the Rules, introduced by Order No. 421/НҚ of 17 July 2026, obliges every Astana Hub participant to contribute to the development of the IT ecosystem, and the volume of that contribution is set by the Fund’s internal documents.

Paragraph 31-1 verbatim:

“For the purposes of developing the digital technology industry, an Astana Hub participant assumes counter-obligations directed at developing the IT ecosystem, disseminating knowledge, experience and best practice, developing human capital, raising professional competencies, promoting employment in the digital technology industry, stimulating industry interaction and/or supporting innovation activity. The volume of counter-obligations is determined on a differentiated basis, taking into account the participant’s headcount and the volume of its financial and economic activity, in the manner established by the Fund’s internal normative documents. Performance of those obligations is effected through the Fund’s web resource, which provides for recording and monitoring their fulfilment.”

Seven directions, among which the participant chooses — note the “and/or” closing the list:

No.	Direction of counter-obligations
1	Developing the IT ecosystem
2	Disseminating knowledge, experience and best practice
3	Developing human capital
4	Raising professional competencies
5	Promoting employment in the digital technology industry
6	Stimulating industry interaction
7	Supporting innovation activity

Three structural features determine the provision’s practical weight.

First: the volume of the obligation is not set by a normative act. It is determined “in the manner established by the Fund’s internal normative documents”. The content of the participant’s duty is therefore fixed not by a ministerial order registered with the Ministry of Justice, but by a Fund document that is not a normative legal act and is not published in the State Register.

Second: obligations are differentiated by two measures — the participant’s headcount and the volume of its financial and economic activity. A large participant carries more than a startup. No scale appears in the Rules.

Third: performance is recorded automatically. Obligations are performed “through the Fund’s web resource, which provides for recording and monitoring their fulfilment”. The Fund receives not the participant’s report on performance but its own record of it.

The sanction for non-performance is direct and severe — unlike the paragraph 33 report. Subparagraph 7) of paragraph 28, as restated by the same Order No. 421/НҚ, makes a ground for early termination “failure by the Astana Hub participant to perform the obligations provided for by paragraph 31-1 of these Rules and by the standard contract on the conditions of activity of an Astana Hub participant”. Paragraph 30 places that ground among those referred to the Commission, which decides on early termination where grounds exist.

The two new 2026 duties compared:

Feature	Paragraph 33 report	Paragraph 31-1 counter-obligations
Who is caught	Only participants with income above 30,000 MCI	All participants
Volume set by	The Rules	The Fund’s internal documents
Frequency	Annually, by 20 July	Not fixed by the Rules
Form of performance	Report and/or conclusion confirmed by an auditor	Through the Fund’s web resource
Direct sanction for failure	None in paragraph 28	Subparagraph 7) of paragraph 28 — early termination
Who decides consequences	—	The Commission under paragraph 30

Author’s assessment: paragraph 31-1 changes the character of the regime more than the reporting requirement does. Until July 2026 a participant’s relationship with the Fund was built around meeting formal criteria and paying membership fees. Paragraph 31-1 adds a duty of substantive contribution whose scope a participant cannot determine from the text of any normative act, and which is backed by the Rules’ strongest sanction. The practical consequence: the Fund’s internal documents setting the scale of counter-obligations should be requested before an application is filed and tracked as carefully as amendments to the Rules themselves.

Paragraph 31 is the general provision to which paragraph 31-1 is an addition. A participant assumes the counter-obligations established by the Rules, by the Fund’s internal normative documents and by the standard contract on the conditions of activity of an Astana Hub participant. The standard contract appears four times in the Rules — in paragraphs 18, 19, 28 and 31 — and is a precondition both for the issue of the certificate and for inclusion in the List of Participants.

Reporting and Monitoring: What a Participant Files Through the Year

Beyond the annual paragraph 33 report, a participant files a quarterly activity report, answers the Fund’s requests within ten working days, and pays membership fees quarterly.

The full calendar of obligations owed to the Fund:

Obligation	Deadline	Provision
Membership fees on income for the preceding quarter	by the 25th day of the month following the expired quarter	para 21
Quarterly report on activity carried out	by the 20th day of the month following the reporting quarter	para 39
Documents on request within monitoring	10 working days from receipt of the request	para 38
Tax accounting information and accounting statements on the Fund’s request	10 working days from receipt of the request	para 32
Copies of statistical reporting and tax returns on the Fund’s request	10 working days from receipt of the request	para 32
Annual report and/or conclusion on the structure of income, confirmed by an auditor — where income exceeds 30,000 MCI	annually by 20 July	para 33
Notice of re-registration or liquidation of the legal entity	10 working days from the event	para 34
Notice of withdrawal from further imple­menta­tion of the project	10 working days before taking the decision	para 29
Application to extend the term of participation	not later than 10 working daysbefore expiry	para 25

The form and content of the quarterly report are determined by an internal normative document of the Fund — paragraph 39 says so expressly. The reporting period is the calendar quarter.

Monitoring — paragraph 4 of Chapter 3 of the Rules. Paragraph 36 states the purpose: “to reflect the actual progress of implementation of the participant’s project”. Paragraph 37 includes two elements in monitoring:

•          1) a quarterly report on the progress of activity and project implementation with an analysis of results achieved;

•          2) additional information requested by the Fund within monitoring.

On the results of monitoring the Fund prepares a conclusion on the expediency or inexpediency of further implementation of the participant’s project — paragraph 40 as restated by Order No. 421/НҚ. A conclusion of inexpediency is the first ground for early termination under subparagraph 1) of paragraph 28 and goes to the Commission under paragraph 30.

That chain — monitoring, conclusion of inexpediency, Commission — is the real mechanism by which a participant leaves the regime. It operates with no connection to tax and without any court act: the Fund’s view on monitoring and a Commission decision suffice. Author’s assessment: for a participant this means the quarterly reporting under paragraph 39 is not a formality but the principal channel through which the Fund forms its view of the project’s viability.

Confidentiality — paragraph 35. Technical, economic and commercial information submitted by a participant or by the Fund in connection with that participant’s activity is confidential and may not be disclosed to third parties without the prior written consent of the participant or the Fund.

Paragraph 32 as restated in July 2026 significantly widened the Fund’s access to data. Previously it covered information required for tax accounting purposes and information from accounting statements. The current text adds a second limb: copies of state statistical reporting and of tax returns (calculations) for the taxes, fees and duties the participant pays.

The practical point of the widened paragraph 32: the Fund can verify a participant’s income structure against its own tax returns, without waiting for the annual paragraph 33 report and without approaching the tax authority. Any divergence between the corporate income tax return and the report on income structure becomes visible inside a single organisation.

The duty to retain documents on foreign employees sits outside the Rules. Paragraph 4 of article 7-1 of Law No. 207-V obliges the Fund and Astana Hub participants to hold and retain, for each foreign national and stateless person engaged, documents confirming their qualifications. No retention period is prescribed by the law.

The general shape of a Kazakh company’s tax reporting and the VAT registration mechanics are set out in VAT in Kazakhstan 2026: Registration, the 10,000 MCI Threshold and the 16% Rate.

Early Termination: Eight Grounds and Who Decides

Participation in Astana Hub ends either on schedule or early, and there are eight early grounds. Only three of them go to the Commission — the rest operate automatically.

The complete list under paragraph 28 of the Rules as restated by Order No. 421/НҚ:

Subparagraph	Ground	Decided by
1)	The Fund establishes the inexpediency of further imple­menta­tion of the project on the results of monitoring under paragraph 4 of Chapter 3	Commission(para 30)
2)	Achievement of the planned results	Commission(para 30)
3)	The participant’s withdrawal from further imple­menta­tion of the project within the Fund’s programmes	automatic
4)	Failure to submit the information and reports provided for by paragraphs 37, 38 and 39 of the Rules	automatic
5)	Liquidation of the participant legal entity	automatic
6)	Non-payment of membership fees under paragraph 21 of the Rules	automatic
7)	Failure to perform the obligations provided for by paragraph 31-1 of the Rules and by the standard contract	Commission(para 30)
8)	Establishment of the fact of activity prohibited by law, confirmed by a court act that has entered into force	automatic

Paragraph 30 sets the procedural dividing line verbatim: “In the cases provided for by subparagraphs 1), 2), 7) of paragraph 28 of these Rules, the Fund refers the question of early termination of the Astana Hub participant’s participation to the Commission. Where the grounds provided for by subparagraphs 1), 2), 7) of paragraph 28 of these Rules exist, the Commission takes the decision on early termination of participation.”

The ground worth thinking about in advance is subparagraph 2): “achievement of the planned results”. It is the only ground on which participation ends not for a breach but for success. A project that has met the objectives of its business plan has formally exhausted the basis for participation. Author’s assessment: the practical consequence is that the business plan submitted on registration determines not only admission but the horizon of membership; a company intending to use the reliefs until 2029 should not frame its stated results as achievable within one or two years.

Scheduled completion — paragraph 27: expiry of the term of participation stated in the certificate of registration. Extension is available on application filed not later than 10 working days before expiry (paragraph 25).

Subparagraph 8) appeared only in July 2026 — until then paragraph 28 had seven subparagraphs. Order No. 421/НҚ added the eighth ground and drafted it from the outset with the qualification of a court act that has entered into force. The current text moves the question of prohibited activity from the administrative to the judicial sphere and removes the Fund’s ability to terminate participation on its own legal assessment.

What the Rules do not provide — and this is a gap of principle.

The Rules contain no provision at all on the tax consequences of exclusion. Neither paragraph 28 nor paragraph 30 nor any other provision links early termination to loss or recalculation of tax reliefs. Those consequences arise exclusivelyunder the Tax Code — through paragraph 4 of article 739 — and they arise not because the participant was removed from the register but because it ceased to meet the conditions of article 17.

The Rules set no time limit for notifying a participant of the Commission’s decision on early termination. The five-day notification in paragraph 17 applies only to decisions on registration or refusal of registration.

The Rules establish no appeal procedure against a Commission decision on early termination. Author’s assessment: in the absence of a special procedure the general appeal route under the Administrative Procedural Code of the Republic of Kazakhstan applies, but the Rules do not say so.

> The relationship between the two statuses in one sentence: removal from the register automatically destroys entitlement to the reliefs, but losing entitlement to the reliefs does not require removal from the register. Subparagraph 1) of paragraph 1 of article 17 of the Tax Code requires registration with the Fund as a participant — without it, every other condition is beside the point. The converse does not hold: a participant that keeps its registration but fails the 90 per cent threshold loses the relief while remaining on the List of Participants.

Nineteen Priority Activities: the Complete List

The List of priority ICT activities contains nineteen items and was approved by Order No. 521/НҚ of 20 October 2025, in force from 1 January 2026. As at August 2026 it has not been amended once.

The order was issued under paragraph 2 of article 17 of the Tax Code and repealed three earlier instruments:

No.	Repealed instrument	MoJ registration
1	Order of the Minister of Digital Development, Defence and Aerospace Industry of 11.04.2019 No. 37/НҚ “On Approval of the List of Priority ICT Activities and the Own-Production Criteria”	No. 18523
2	Order of the Ministry of Digital Development of 19.04.2022 No. 130/НҚ	No. 27788
3	Order of the acting Minister of Digital Development of 20.09.2023 No. 413/НҚ	No. 33450

The nineteen items in full:

No.	Priority activity
1	Development, imple­menta­tion, support, enhancement, modification and sale of software and software products, including the sale of services integrated into software and hardware capabilities — placement of paid content and sale of built-in additional functionality
2	Creation, pilot and industrial operation, imple­menta­tion, enhancement, modification and support of information systems — excluding information systems of state bodies
3	Data processing activity (knowledge discovery in databases) using proprietary or third-party software
4	Fundamental and applied research, experimental development in the natural and technical sciences, research and development work in the ICT field and the comme­rciali­sation of its results
5	Development and discrete stages of development of technologies, devices and systems of micro-, opto- and nanoe­lectro­nics, microe­lectrome­chanics, and printed circuit board assembly
6	Development and discrete stages of development of technologies, devices and systems of robotics
7	Development of technologies, devices and systems of radiolocation, radio­navi­gation, radio communication, radio control and radio frequency ide­ntifi­cation
8	Development and production of technologies, equipment and devices in ICT, teleco­mmuni­cations technologies, and biometric devices and systems
9	Development, production, installation and configuration of technical and software means of information processing in protected execution, and of software and hardware-software means in the field of information security
10	Development and support of software and hardware-software complexes using cloud computing technologies
11	Development and support of software and hardware-software complexes based on or using blockchaintechnology
12	Development and sale of unmanned vehicle control systems, and of satellite navigation, mobile communication and emergency call systems and devices for transport
13	Development and discrete stages of development of technologies, devices and systems of artificial intelligence
14	Providing, over the internet, software and hardware capabilities for establishing contacts and concluding transactions between sellers and buyers — a marketplace — on condition that the rights holder in the software is the Astana Hub participant itself
15	Development and comme­rciali­sation of the concept of a computing and communication network of physical objects with embedded interaction technologies — the internet of things
16	Development, support and sale of computer, mobile and online games (video games), including the placement of paid content and the sale of built-in additional functionality
17	Provision of training services in the ICT field along the directions listed in the item — from software architecture and admi­nistra­tion and product management through to video game development and programming languages
18	Development and discrete stages of development of virtual and augmented reality technologies, devices and programs
19	Services providing integrated computing infra­stru­cture for computing operations and data processing — excluding data centres providing infra­stru­cture to persons engaged in digital mining

Four exclusions inside the list, each of which removes an entire market segment:

•          item 2 — information systems of state bodies are outside the priority activities;

•          item 14 — a marketplace qualifies only where the participant itself is the rights holder in the software; operating on someone else’s platform does not count;

•          item 19 — data centres serving digital mining are expressly excluded;

•          item 17 — training counts only for the closed list of directions set out within the item.

The exclusion of state information systems from item 2 is easy to miss and expensive to ignore. A company deriving a substantial share of its revenue from developing and supporting state bodies’ systems cannot count that revenue in the numerator of the 90 per cent threshold under article 17 of the Tax Code. From 1 January 2029 subparagraph 9) of paragraph 7 of the Rules will add a 50 per cent cap on income from state bodies and the quasi-state sector — so the same segment will be constrained twice, at two different levels.

The own-production criterion — the second half of Order No. 521/НҚ — is a single criterion, not several.Verbatim: “The Astana Hub participant holds an extract from the register of Kazakhstani producers in accordance with paragraph 8 of article 51-1 of the Law of the Republic of Kazakhstan ‘On Industrial Policy’”. The repealed 2019 order spoke of “criteria” in the plural; the instrument in force reduces the requirement to a single document.

The criterion does not apply to everyone. Subparagraph 3) of paragraph 1 of article 17 of the Tax Code ties it to the case of producing and selling goods. A participant that supplies services only and produces no goods need not produce an extract from the register of Kazakhstani producers.

The Tax Layer: Chapter 82 and Three Streams of Income

An Astana Hub participant is not exempt from corporate income tax — it reduces the computed amount of tax by 100 per cent. The distinction is not semantic: the duty to compute the tax and file returns survives.

The reliefs sit in Chapter 82 of Section 17 of the Tax Code — four articles:

Article	Heading
738	Taxation of Astana Hub participants
739	General provisions — opens paragraph 1, “Procedure for reducing corporate income tax by Astana Hub participants”
740	Reduction of CIT on income from intellectual property objects
741	Reduction of CIT on income from the provision of info­rmati­zation services

Paragraph 1 of article 738 lists five reliefs available to participants meeting the conditions of article 17:

•          1) reduction of the computed CIT amount by 100 per cent under paragraph 1 of Chapter 82;

•          2) VAT exemption for turnover on the sale of goods — subparagraph 33) of article 474;

•          3) VAT exemption for turnover on the sale of works and services — subparagraph 34) of article 474;

•          4) VAT exemption for the import of imported goods — subparagraph 11) of paragraph 1 of article 479;

•          5) exclusion of employees’ income from the object of social tax — subparagraph 3) of paragraph 2 of article 556 (the relief is limited by the employee’s citizenship — analysed below).

Paragraph 1 of article 739 divides a participant’s income into three streams, each with its own mechanics:

Income stream	How the reduction works	Basis
1) Income from intellectual property objects	under article 740 — through the nexus coefficient	art. 739(1)(1)
2) Income from the provision of info­rmati­zation services	under article 741 — subject to five conditions	art. 739(1)(2)
3) Income not falling within 1) or 2)	in the amount of the computed CIT — with no further conditions	art. 739(1)(3)

What is reduced is the tax computed under article 345 of the Tax Code. That is the article named in paragraph 1 of article 739 and again in paragraph 5 of the same article.

What counts as an intellectual property object — paragraph 2 of article 739. Software protected by the Law “On Copyright and Related Rights”, and an invention, utility model or industrial design in the field of informatization under the Patent Law of the Republic of Kazakhstan, being the result of carrying on the priority activities prescribed for Astana Hub participants.

The nexus coefficient — a construction in article 740 with no counterpart in the previous Code. It is computed from the structure of expenditure on creating the intellectual property object — own costs, outsourcing to unrelated parties, outsourcing to related foreign parties, and acquisition costs — and is capped at one: where the computed value exceeds 1, the coefficient is taken as 1. Author’s assessment: this is a direct implementation of the OECD modified nexus approach under BEPS Action 5. The practical meaning: the more of the development that is outsourced to related foreign parties, the smaller the share of intellectual property income that reaches the zero rate.

The formula for the nexus coefficient is set by paragraph 3 of article 740 of the Tax Code: K = (Rown + Routsourcing 1) × 1.3 ÷ (Rown + Routsourcing 1 + Routsourcing 2 + Racquisition). The same provision defines the terms:

•          Rown — the participant’s costs relating to the intellectual property object, excluding the cost of acquiring it;

•          Routsourcing 1 — outsourcing costs incurred with persons who are not related parties;

•          Routsourcing 2 — outsourcing costs incurred with related parties situated outside the Republic of Kazakhstan;

•          Racquisition — the cost of acquiring the intellectual property object.

The 1.3 multiplier is the “uplift” of the modified nexus approach: it allows the coefficient to reach one even where a moderate share of the cost is external, which is precisely why the provision separately states that a computed value above 1 is taken as 1.

Paragraph 1 of article 740 applies only where the participant holds exclusive proprietary rights in the intellectual property object. That is a standalone condition: income under a licence obtained from a third party does not fall within article 740.

Article 741 has two levels, and the first narrows its scope far more than is generally assumed.

Paragraph 1 of article 741 defines what counts as income from the provision of informatization services — just four items:

•          1) services of research, analysis, design, adaptation and configuration of software;

•          2) technical support services;

•          3) software testing services;

•          4) services of training software users.

Set that against nineteen priority activities in the List, and four items in article 741(1). Income from developing one’s own product, from a marketplace, from video games, from cloud infrastructure or from artificial intelligence systems does not fall within article 741(1). It falls either within intellectual property income under article 740, or within “other income” under article 739(1)(3) — and other income is reduced by 100 per cent with no additional conditions at all. Author’s assessment: this is one of the most useful structural features of the regime and it is almost never explained — the five conditions of article 741 apply to the services model, not to the product model.

Paragraph 2 of article 741 sets five conditions for applying the zero rate to services income:

No.	Condition under article 741(2)
1)	The contract for the provision of info­rmati­zation services does not conflict with the requirements of Kazakhstan law
2)	Employment contracts are concluded in accordance with the Labour Code of the Republic of Kazakhstan
3)	The participant’s headcount permits it to provide the services concerned
4)	The employees hold the necessary qua­lifica­tions and/or length of service and/or experience
5)	The volume of expenditure incurred corresponds to the volume actually necessary to provide the service

The second part of article 741(2) is the delegating provision that produced Order No. 599/НҚ. Verbatim: “Compliance with the conditions set out in subparagraphs 3), 4) and 5) of the first part of this paragraph is established in the manner determined by the authorised body in the field of informatization in agreement with the central authorised body for state planning and the authorised body”. Note the scope of the delegation: the ministerial procedure covers only conditions 3), 4) and 5), not conditions 1) and 2), and is agreed with two bodies rather than the four that agree the List of priority activities under paragraph 2 of article 17.

> Conditions 3), 4) and 5) are a test of substance, not of documentation. Headcount, qualifications and the proportionality of costs are examined on the merits, and in a procedure set by the ministry rather than the tax authority. A company with two employees and several billion tenge of revenue from “technical support services” will not pass subparagraph 3), however impeccably its contracts are drafted.

The Other Reliefs: Income Tax, Social Tax, VAT and Payments to Non-Residents

Alongside the zero CIT, an Astana Hub participant obtains relief from individual income tax for its employees, a partial exclusion of their income from the social tax base that is limited by the employee’s citizenship, a reduction of taxable income for gains on the sale of its shares and participation interests, VAT exemption on three grounds, and exemption from withholding tax on two categories of payment to non-residents.

Relief	Provision of Code No. 214-VIII	Conditions
Employees’ income reduces the individual income tax base at source	subparagraph 3) of article 429	No thresholds, no qua­lifica­tions: “income of employees of legal entities that are Astana Hub participants”
Social tax — employees’ income excluded from the object only as regards employees who are not citizens of Kazakhstan	subparagraph 3) of paragraph 2 of article 556, third sub-clause	The third sub-clause returns the income of Kazakh-citizen employees to the object
Taxable income reduced by the gain on the sale of a participant’s shares and participation interests	subparagraph 10) of the first part of paragraph 2 of article 337	Relief sits with the seller of the shares or interest
VAT — turnover on the sale of goods produced and sold by participants	subparagraph 33) of article 474	Compliance with article 17
VAT — turnover on the sale of works and services	subparagraph 34) of article 474	Compliance with article 17
VAT on imports of goods	subparagraph 11) of the first part of paragraph 1 of article 479	Three cumulative conditions, including use exclusively for priority activities
Reverse-charge VAT — acquisition of works and services from a non-resident is not a taxable turnover	subparagraph 3) of paragraph 3 of article 454	Acquisition for priority activities
Payments to non-residents for specified services — not taxable	subparagraph 11) of article 681	Closed list of services; carve-out for persons registered in a state with preferential taxation
Royalties to non-residents — not taxable	subparagraph 13) of article 681	Payment for the purposes of activity on the List of priority activities

The employee income tax relief is drafted with extreme brevity and no conditions. Article 429, “Reduction of an employee’s income taxable at source of payment”, contains nine subparagraphs, and subparagraph 3) reads in full: “income of employees of legal entities that are Astana Hub participants”. The provision contains no monetary threshold, no citizenship restriction and no requirement as to role. That is true of the income tax specifically: for social tax a citizenship restriction does exist, and it is analysed next.

The exclusion from the social tax object does not cover every employee — this is the most under-reported detail of the regime. Subparagraph 3) of paragraph 2 of article 556 reduces the social tax object by the income established by article 429, with the exception of two items: income under subparagraph 2) of article 429 and — in its third sub-clause — “income established by subparagraph 3) of article 429 of this Code as regards the income of employees who are citizens of the Republic of Kazakhstan”. The clause removes the income of Kazakh citizens from the deduction, and therefore keeps it inside the object.

The practical conclusion: an Astana Hub participant pays social tax on the salaries of employees who are citizens of the Republic of Kazakhstan in the ordinary way. Only the income of employees who are not Kazakh citizens is taken out of the social tax object. It is precisely this third sub-clause that subparagraph 3) of paragraph 2 of article 848 names among the provisions operating until 1 January 2029. Author’s assessment: a payroll model built on the assumption that “there is no social tax” overstates the net benefit of the regime for a team staffed with Kazakh specialists. The text was checked against two independent mirrors — pavlodar.com and kodeksy-kz.com — and matches word for word.

The reduction of taxable income for capital gains is a relief almost nobody writes about. Subparagraph 10) of the first part of paragraph 2 of article 337 of the Tax Code reduces taxable income by “income from the gain on the sale of shares issued by Astana Hub participants and of participation interests in the charter capital of an Astana Hub participant”. The relief operates not at the level of the participant but at the level of the seller of its shares or interest, and it is named in the list in subparagraph 3) of paragraph 2 of article 848 alongside article 17 and Chapter 82 — that is, it runs until 1 January 2029.

The relief on service payments to non-residents is narrow and enumerative. Subparagraph 11) of article 681 covers income “from the provision of consulting, marketing and engineering services, information security services, and works on the creation of data centres”, paid by a legal entity that is an Astana Hub participant. Software development by a non-resident does not appear on that list. The provision applies on condition that the works and services are acquired for carrying on activities included in the List of priority activities.

The royalty relief is new to Code No. 214-VIII. Subparagraph 13) of article 681 exempts the income of a non-resident legal entity in the form of royalties paid by an Astana Hub participant, provided the payment is made for the purposes of activity on the List of priority activities. Both subparagraphs — 11) and 13) — carry the same carve-out: they do not apply to the income of a person registered in a state with preferential taxation.

Dividends to non-residents are not exempt, and that is the starting position rather than a change. Article 681 contains no subparagraph exempting dividends paid by an Astana Hub participant. Dividends are taxed at source under the general rules of Section 15 of the Tax Code. Author’s assessment: the practical implication for a holding structure is that a zero CIT at the level of the Kazakh company does not make profit extraction free; the question is answered by a double tax treaty, not by the Astana Hub regime. The withholding mechanics and treaty relief are set out in Withholding Tax in Kazakhstan 2026, and the profit-distribution route in Dividends and Profit Repatriation from a Kazakh LLP in 2026.

The import VAT exemption is the only relief with a compound condition. Subparagraph 11) of the first part of paragraph 1 of article 479 requires three conditions to be met simultaneously: inclusion of the goods in the list of goods whose import is exempt from VAT, approved by the authorised body in the field of informatization in agreement with the central authorised body for state planning and the authorised body; customs formalities completed in accordance with EAEU and/or Kazakh customs law; and importation of the goods exclusively for use in carrying on priority activities. There is no separate fourth condition — the common assertion that there are “four conditions” is not supported by the text of the article.

Note that the reliefs are not all tied to article 17 in the same way. Subparagraphs 33) and 34) of article 474 and subparagraph 3) of paragraph 3 of article 454 expressly require compliance with the conditions of article 17. Subparagraph 11) of paragraph 1 of article 479 and subparagraph 3) of article 429 are drafted by reference to Astana Hub membership alone and do not cite article 17. Author’s assessment: no practical divergence should be expected — article 17 defines the very concept of a participant for the purposes of the Code — but in a dispute the difference in drafting works in the taxpayer’s favour on income tax and import VAT.

Obligatory payments Chapter 82 does not touch directly. Obligatory pension contributions, compulsory social medical insurance deductions and contributions, and social deductions are not governed by the Tax Code and do not form part of Chapter 82. Their base is set by the Social Code, by the Law “On Compulsory Social Medical Insurance” and by a Government resolution. But all three instruments cross-refer to paragraph 1 of article 400 of the Tax Code, and subparagraph 17) of paragraph 1 of article 400 includes among the reducing items “the income of an employee specified in article 429 of this Code”. It is through that chain that the Astana Hub regime reaches payroll charges — and it reaches each of them differently.

The mechanism has to be read carefully, because the double-negative construction is easy to read backwards. Each of the three instruments subtracts from the base “the income by which income taxable at source of payment is reduced under paragraph 1 of article 400 of the Tax Code”, and then adds the qualification “with the exception of the income specified in subparagraphs … of article 429”. The qualification removes the named subparagraphs from the deduction — that is, it returns the corresponding income to the base of the payment. If subparagraph 3) of article 429 is named, the payment is due; if it is not named, it is not.

Payment	Provision and the subparagraphs of article 429 it names	Is subparagraph 3) named?	Result for a participant’s employee
Individual income tax	subparagraph 3) of article 429 of the Tax Code — a direct provision	—	Not withheld
Social tax	third sub-clause of subparagraph 3) of paragraph 2 of article 556	yes, as regards Kazakh citizens	Payable on the income of Kazakh citizens; not payable on the income of foreign employees
Social deductions	paragraph 1 of article 245 of the Social Code — subparagraphs 1), 2), 3) and 7)	yes	Payable in the ordinary way
Obligatory pension and professional pension contributions	paragraph 7 of the Rules approved by Government Resolution No. 525 of 30 June 2023 — subparagraphs 3) and 8)	yes	Withheld in the ordinary way
Compulsory medical insurance deductions and contributions	paragraph 1 of article 29 of Law No. 405-V — subparagraphs 2) and 4)	no	Not payable

The conclusion is worth committing to memory in full: of five payroll charges, the Astana Hub regime removes two and a half. Individual income tax is not withheld on any employee. Social tax falls away only on the income of employees who are not Kazakh citizens. Medical insurance deductions and contributions are not payable. Social deductions and obligatory pension contributions are payable in full. Author’s assessment: the claim that “an Astana Hub participant’s payroll is free of taxes and contributions” is wrong on three of the five, and it is that claim that most inflated savings models are built on.

A note on reliability. Paragraph 1 of article 245 of the Social Code was checked against the pavlodar.com mirror in its 2026 redaction; paragraph 1 of article 29 of Law No. 405-V against two independent mirrors, kodeksy-kz.com and zakon.mybuh.kz, which give the same pair of subparagraphs 2) and 4); and paragraph 7 of Rules No. 525 against the zakon.mybuh.kz mirror in the redaction that cross-refers to articles 400 and 429 of the new Code. Employer obligatory pension contributions (ОПВР) are governed by a separate instrument, Government Resolution No. 540 of 3 July 2023, whose cross-references were re-pointed to the new Tax Code by Government Resolution No. 939 of 7 November 2025; the accessible mirrors as at the date of this analysis still serve the pre-amendment redaction of No. 540, so the position on employer pension contributions should be confirmed separately. No clarification from the State Revenue Committee on the payroll charges of Astana Hub participants had been published as at the date of publication — the conclusion above rests on a direct reading of the instruments. The full payroll charge on a Kazakh employer is set out in Employer Payroll Taxes and Contributions in Kazakhstan 2026.

Currency control is untouched by the regime. Law No. 167-VI of 2 July 2018 “On Currency Regulation and Currency Control” mentions neither Astana Hub, nor the autonomous cluster fund, nor an international technopark. Participants are subject to the ordinary currency regime: the repatriation requirement, contract registration numbers and general reporting. That framework is analysed in Currency Control in Kazakhstan 2026.

Confirming Entitlement to the Zero CIT: Order No. 599/НҚ

Entitlement to the 100 per cent CIT reduction on income from informatization services is confirmed through a separate annual procedure run by the Fund, not by the tax authority.

The basis is Order of the Deputy Prime Minister — Minister of Artificial Intelligence and Digital Development No. 599/НҚ of 27 November 2025, “On Approval of the Rules for Establishing the Compliance of an Astana Hub Participant with the Conditions for Reducing Corporate Income Tax by 100 Per Cent on Income from the Provision of Informatization Services”, registered with the Ministry of Justice on 28 November 2025 under No. 37492, in force from 1 January 2026. It was issued “in accordance with paragraph 2 of article 741 of the Tax Code of the Republic of Kazakhstan”.

The procedure in full:

Stage	Time limit	Provision of Rules No. 599/НҚ
Application through the Fund’s web resource	not later than 1 February of the year following the reporting period	para 5
The Fund verifies actual indicators against the business plan	25 calendar days	para 7
Suspension of review to remedy defects	up to 5 working days	para 8
Revision of the decision during the calendar year and notification of the tax authorities	—	para 11

Three grounds for refusal — paragraph 10:

•          the documents were not submitted within the prescribed period;

•          actual indicators fall short of the business plan indicators by more than 50 per cent;

•          the defects were not remedied within the prescribed period.

The 50 per cent shortfall threshold is the most underestimated parameter of the whole regime. It appears neither in the Tax Code nor in the Rules of activity of the Fund, and exists only in Order No. 599/НҚ. The practical meaning: the business plan submitted on registration becomes an annual performance benchmark. Revenue, headcount or investment figures stated in it and missed by more than half give the Fund a ground to refuse confirmation of entitlement to the zero CIT — with every other condition perfectly satisfied.

Paragraph 11 closes the loop to the tax authority. The decision may be revised during the calendar year, and changes are communicated to the tax authorities. Confirmation is therefore not final for the year: the Fund may change its decision and notify the tax committee.

The 1 February deadline coincides with no tax filing date. The corporate income tax return for the tax period is filed later, which gives the participant the opportunity to obtain the Fund’s decision before filing — provided the application was made on time.

Three procedures that are easily confused:

Procedure	Who performs it	Timing	What it establishes	Basis
Report on the structure of income	Auditor; filed with the Fund	by 20 July	Income structure and corre­spo­ndence with the List of priority activities	para 33, Rules No. 703/НҚ
Confirmation of entitlement to the CIT reduction	The Fund	application by 1 February, review 25 calendar days	Compliance with subparagraphs 3), 4) and 5) of article 741(2)	Rules No. 599/НҚ
Quarterly activity report	Participant; filed with the Fund	by the 20th of the month following the quarter	Progress of project imple­menta­tion	para 39, Rules No. 703/НҚ

The Order No. 599/НҚ procedure covers only one of the three income streams. It relates exclusively to income from informatization services under article 741 — that is, to the four items in paragraph 1 of that article. Income from intellectual property objects under article 740 and other income under article 739(1)(3) do not pass through this procedure at all.

> Author’s assessment: the confirmation architecture of 2026 is built so that a participant deals with the Fund three times a year on three different footings, and none of those interactions substitutes for another. The paragraph 33 report does not confirm entitlement to the relief. The Order No. 599/НҚ decision does not confirm satisfaction of the 90 per cent threshold. The quarterly report bears on neither. A company that believes “we passed the audit, so the tax position is fine” has misread the architecture of the regime itself.

The Life of the Regime: 1 January 2029

The Astana Hub tax reliefs run until 1 January 2029. The sunset is set in the Tax Code itself — by subparagraph 3) of paragraph 2 of article 848 — and not in a separate enactment law.

Code No. 214-VIII has no separate enactment law. Commencement is governed by the final article of the Code itself — article 848 of Section 22, “Final and Transitional Provisions”. Paragraph 1: the Code comes into force on 1 January 2026, except article 189 (from 1 July 2026) and article 92 and Chapter 90 (from 1 January 2027).

Subparagraph 3) of paragraph 2 of article 848 lists the provisions operating until 1 January 2029. On the Astana Hub side these are:

Provision	What it governs
article 17	Definition of an Astana Hub participant and the 90 per cent threshold
subparagraph 10) of the first part of paragraph 2 of article 337	Reduction of taxable income by the gain on the sale of a participant’s shares and interests
article 343	Treatment of a loss on an intellectual property object in priority activities
subparagraph 3) of article 429	Reduction of employees’ income for individual income tax
subparagraph 3) of paragraph 3 of article 454	Reverse-charge VAT
subparagraphs 33) and 34) of article 474	VAT exemption for turnover on goods and on works and services
subparagraph 11) of the first part of paragraph 1 of article 479	VAT exemption on imports
third sub-clause of subparagraph 3) of paragraph 2 of article 556	The carve-back that keeps Kazakh-citizen employees inside the social tax object
Chapter 82	Articles 738 to 741 in their entirety
subparagraph 11) of article 681	Payments to non-residents for consulting, marketing, engineering and information security services and data centre construction

One caution when reading subparagraph 3) of paragraph 2 of article 848 in the original. The enumeration is long and mixes Astana Hub provisions with unrelated ones: alongside subparagraphs 33) and 34) of article 474 it also names subparagraph 48), which concerns an organisation specialising in improving the quality of second-tier banks’ loan portfolios and has nothing to do with Astana Hub. Only the provisions listed in the table above form the Astana Hub package.

The sunset is drafted elegantly and radically at once: article 17 lapses together with Chapter 82. When on 1 January 2029 the definition of an Astana Hub participant ceases to operate for tax purposes, every cross-reference to that concept in articles 429, 454, 474, 479, 556 and 681 is left without a referent. They will not need to be repealed individually — they will empty automatically.

One asymmetry in the list deserves separate attention. Subparagraph 3) of paragraph 2 of article 848 names subparagraph 11) of article 681 — the exemption for service payments to non-residents. Subparagraph 13) of article 681 — the royalty exemption — is absent from the list.

Author’s assessment: on the face of the text the exemption for royalties paid by an Astana Hub participant to a non-resident is not limited to 1 January 2029, while the exemption for service payments is. Subparagraph 13) is an innovation of Code No. 214-VIII, and its omission from the list may be either deliberate or an oversight in compiling a long enumeration. The point has been verified directly against the consolidated text of article 848; even so, until an official clarification appears, a long-term royalty structure should not be built on that asymmetry alone.

What happens on 1 January 2029, taking all the instruments together:

What	Basis
All tax reliefs for participants cease	art. 848(2)(3) of the Tax Code
The requirement of export orientation takes effect	para 7(8) of Rules No. 703/НҚ; para 5 of the order
The 50 per cent cap on income from state bodies and the quasi-state sector takes effect	para 7(9) of Rules No. 703/НҚ; para 5 of the order

The coincidence of dates does not look accidental. The two harshest admission conditions switch on at precisely the moment the tax reliefs switch off. Author’s assessment: the most plausible reading is that the legislator built a review point for the entire regime into 2029 and prepared tightened criteria in case it is extended. A structure planned “to 2029 and beyond” cannot ignore that fork.

Participant status itself does not end on 1 January 2029. What expires is the tax provisions, not Law No. 207-V, Rules No. 703/НҚ or the List of priority activities. A participant remains a participant — without the reliefs, and with two additional admission conditions.

By comparison, the AIFC horizon is of a different order. The tax exemptions of participants of the Astana International Financial Centre are established by article 6 of Constitutional Law of the Republic of Kazakhstan No. 438-V of 7 December 2015 “On the Astana International Financial Centre”, and the formula “until 1 January 2066” recurs in paragraphs 2, 3, 4, 6 and 7 of that article — for the Centre’s bodies, for participants, for specified categories of participants’ income, for individual income tax on foreign employees, and for individuals and legal entities. The exemption for participants carries the qualification “with the exception of the digital asset exchange”. A forty-year difference in horizon matters more, for a long-lived structure, than any difference in rates. A source warning: the consolidation of Constitutional Law No. 438-V on the zakon.uchet.kz and prg.kz mirrors stops at 1 April 2023, so the text in force should be checked against the consolidated version published by the AIFC Court in December 2025. The comparison between the two Kazakh regimes is set out in AIFC or LLP: Choosing a Jurisdiction Inside Kazakhstan.

What Happens on Breach: Recalculation from the Start of the Tax Period

Where a taxpayer ceases to meet the conditions of article 17, it applies the generally established taxation regime from the date of the start of the tax period in which the breach occurred. The recalculation is retrospective within the year, but no deeper.

Paragraph 4 of article 739 of the Tax Code, verbatim:

“Where a taxpayer does not comply with the conditions established for Astana Hub participants by article 17 of this Code, that taxpayer applies the generally established taxation regime from the date of the start of the tax period in which the breach was committed.”

What that means in figures. A company on a calendar tax period whose core-activity share fell below 90 per cent in October 2026 loses the reliefs for the whole of 2026, not from October. What is recomputed:

•          corporate income tax — from nil to 20 per cent;

•          individual income tax at source on employees’ income for the entire year;

•          social tax on the same income;

•          value added tax on turnover exempted under subparagraphs 33) and 34) of article 474;

•          reverse-charge VAT under subparagraph 3) of paragraph 3 of article 454;

•          withholding tax on payments to non-residents exempted under subparagraphs 11) and 13) of article 681.

Closed prior years are untouched. Paragraph 4 of article 739 speaks of the tax period in which the breach was committed — not of every period in which the regime was used. Author’s assessment: this is materially softer than several comparable regimes, in which loss of status triggers recalculation across the whole period of relief. But even within a single year the exposure can be large, because six tax positions are recomputed at once rather than one.

The trigger is non-compliance with article 17, not removal from the register. The three conditions of article 17 behave differently:

Condition of article 17	How it is breached	When it surfaces
1) Registration with the Fund as a participant	Early termination under paragraph 28 of the Rules	Immediately and unambiguously
2) Not less than 90 per cent of aggregate annual income from priority activities	A change in the revenue mix	At year end — by computation
3) Goods meeting the own-production criteria	Loss of the extract from the register of Kazakhstani producers	On inspection

Condition 2) is constructed so that a breach can only be detected after the event. The share is measured against aggregate annual income, which is finally known only once the year has closed. A company that signs one large non-core contract in December learns that it has crossed the threshold when the whole year has already been run at the zero rate. This is precisely why the annual report on the structure of income under paragraph 33 of the Rules has practical value irrespective of the absence of a sanction for not filing it: it puts the income-structure calculation in the participant’s hands before the tax authority makes the same calculation.

The no-stacking rule — paragraph 5 of article 739. Verbatim: “An Astana Hub participant is not entitled to apply other provisions of this Code providing for a reduction of corporate income tax computed in accordance with article 345 of this Code by 100 per cent.”

The rule blocks combination with several regimes of the Code at once. The same Section 17 contains Chapter 80 (special economic zones, articles 734 to 735), Chapter 81 (investment contracts, articles 736 to 737) and Chapter 83 (mining and metallurgical complex projects). None of these may be applied by an Astana Hub participant simultaneously with Chapter 82 in respect of a 100 per cent CIT reduction.

The prohibition is mirrored in the Entrepreneurial Code. Law No. 215-VIII of 18 July 2025 added an exclusion for Astana Hub participants to subparagraph 3) of paragraph 4 of article 283-1 of the Entrepreneurial Code, so investment preferences are unavailable to them. The mutual exclusion is drafted from both sides: subparagraph 3) of paragraph 7 of the Rules keeps holders of investment priority projects out of Astana Hub, and the Entrepreneurial Code keeps investment preferences away from Astana Hub participants.

Losses on intellectual property objects follow a special rule. Paragraph 3 of article 739 refers to article 343 of the Tax Code, which sets out how losses on an intellectual property object are accounted for when Astana Hub participants carry on priority activities. Article 343 is likewise included among the provisions operating until 1 January 2029.

> The planning conclusion: the only controllable variable in this construction is the revenue mix. Registration is within the company’s control, the own-production criteria apply only to some, and the 90 per cent threshold depends on which contracts the company signs during the year. Non-core income — consulting outside the List, resale of hardware, rent, income from participation in other legal entities — reduces the numerator and is offset by nothing except the four categories expressly named in the second part of paragraph 1 of article 17.

Foreign Staff: a Five-Year Visa Exists, a Permit Exemption Does Not

Astana Hub membership brings visa advantages for foreign employees, but it does not release a company from obtaining the local executive body’s permit to engage foreign labour.

The basis for the visa advantages is article 7-1 of Law No. 207-V, added by Law No. 220-VIII of 27 September 2025. The article is headed “Specifics of the engagement of foreign labour by the Fund and Astana Hub participants” and contains five paragraphs:

Paragraph	Content
1	Foreign nationals and stateless persons arriving to carry out activity at the Fund obtain an entry visa, agreed with the national security body, at Kazakhstan’s foreign missions or on arrival at international airports of the Republic of Kazakhstan
2	Foreign nationals and stateless persons who are employees of Astana Hub participants or employees of the Fund, and members of their families (spouse, children and dependants, on production of supporting documents), obtain an entry visa valid for up to five years
3	The Fund maintains a record of the foreign labour engaged by it and by participants; the information is submitted to the authorised body for migration, with frequency and procedure determined by the authorised body in the field of digi­tali­sation in agreement with the migration body and the National Security Committee
4	The Fund and participants must hold and retain, for each foreign national engaged, documents confirming their qua­lifica­tions
5	Extension of visas for the persons named in paragraph 2 may, on the Fund’s application, be effected without leaving the Republic of Kazakhstan

What article 7-1 does not contain: any words releasing participants from the permit to engage foreign labour, and any words about quotas. The article governs visas, record-keeping and retention of qualification documents — and nothing else. The proposition that “Astana Hub participants hire foreigners without a permit” does not correspond to the text of the law.

The list of persons for whom no permit is required is set by Government Resolution No. 1041 of 24 November 2023, “On Determining the List of Persons for Whom Permits of Local Executive Bodies to Engage Foreign Labour for Employment Are Not Required”, issued under subparagraph 8) of paragraph 2 of article 36-1 of the Law of the Republic of Kazakhstan “On Population Migration”.

Neither Astana Hub, nor the autonomous cluster fund, nor an international technopark appears anywhere in that list.

What the list does contain, and what is routinely confused with it, is an item on foreign employees engaged by participants and bodies of the Astana International Financial Centre. The exemption is granted to AIFC participants, not to Astana Hub participants. These are two different regimes with different legal foundations, and carrying conclusions across from one to the other is an error.

The two regimes compared on the staffing dimension:

Parameter	Astana Hub	AIFC
Exemption from the permit to engage foreign labour	None	Granted by Resolution No. 1041
Visa for employees and family members	Up to five years, article 7-1 of Law No. 207-V	Under AIFC rules
Visa extension without leaving the country	Yes, on the Fund’s application	—
Visa on arrival at an international airport	Yes, for those arriving for activity at the Fund	—
Duration of the tax reliefs	to 1 January 2029	to 1 January 2066

General exemption grounds available to a participant irrespective of status. Resolution No. 1041 contains categories applicable to any employer: nationals of Eurasian Economic Union member states; one first executive of a Kazakh legal entity and one deputy; business immigrants; and holders of an investor visa. An Astana Hub participant relies on these on ordinary terms — but not by virtue of technopark membership.

Author’s assessment: the staffing block is the most frequent point of divergence between how the regime is marketed and what it legally provides. A five-year visa with extension without departure is a real and substantial advantage, particularly for relocating teams with families. But it does not displace the permit procedure, the quota system, or the requirements on the ratio of Kazakh to foreign employees. A company planning to move several dozen foreign specialists to Kazakhstan must budget for local executive body permits on ordinary terms.

The duty to retain qualification documents is a freestanding requirement of article 7-1(4) and is easily overlooked.It falls on both the Fund and participants, applies to every foreign national and stateless person engaged, and carries no statutory retention period. On inspection, the absence of documents confirming qualifications is a breach of the law regardless of whether a permit was obtained.

The routes to residence and long-term stay in Kazakhstan, including the permanent-residence pilot and the visa categories for remote specialists, are set out in Kazakhstan Residence Permits in 2026.

Step by Step: How to Enter the Regime and Stay in It

Sequence matters: the business plan governs both admission and the annual performance benchmark, and the revenue mix decides the tax question retrospectively.

1.        Match the activity against the List of priority activities under Order No. 521/НҚ. Nineteen items, four internal exclusions. State bodies’ information systems, third-party marketplaces and data centres serving digital mining do not count.

2.        Work through the ten conditions of paragraph 7 of the Rules. Eight operate now, two from 1 January 2029. The absence of branches is tested at the moment of application.

3.        Model the 90 per cent threshold of aggregate annual income under article 17 of the Tax Code. Include the four categories that count towards the numerator: property received free of charge, deposit remuneration, the excess of positive over negative exchange differences, and income from doubtful liabilities.

4.        Identify which of the three income streams your revenue falls into. Intellectual property objects — article 740 and the nexus coefficient. The four service items of article 741(1) — the five conditions of article 741(2). Everything else — article 739(1)(3), with no additional conditions.

5.        Compute the nexus coefficient if development is outsourced. Outsourcing to related foreign parties reduces the share of intellectual property income reaching the zero rate.

6.        Draft the business plan conservatively. It is tested twice: on admission under paragraph 16(1) of the Rules, and annually under paragraph 10 of Rules No. 599/НҚ, where a shortfall of more than 50 per cent is a ground for refusing confirmation of entitlement to the relief.

7.        Ask the Fund for the membership fee and the scale of counter-obligations before applying. Both are set by the Fund’s internal documents and appear in no normative act.

8.        File the electronic application on the Fund’s web resource with the documents under paragraph 9 and the business plan under Annex 1. The application may be completed in English.

9.        Go through the Commission. Fifteen working days for the Fund’s review, ten for the Commission’s decision, five for notification.

10.    Sign the standard contract on the conditions of activity of a participant. The three working days for issuing the certificate and the three for inclusion in the List of Participants both run from signature.

11.    Set up income accounting by stream from day one. The 90 per cent threshold, articles 740 and 741, and the annual paragraph 33 report each require a different cut of the same revenue.

12.    Pay membership fees by the 25th day of the month following the quarter. Non-payment is a standalone ground for early termination under paragraph 28(6).

13.    File the quarterly report by the 20th day of the month following the quarter. Failure to submit reports under paragraphs 37, 38 and 39 is a ground under paragraph 28(4).

14.    Perform the paragraph 31-1 counter-obligations through the Fund’s web resource. Failure goes to the Commission under paragraph 30.

15.    File the application for confirmation of the CIT reduction by 1 February of the year following the reporting period — Rules No. 599/НҚ.

16.    Arrange the auditor-confirmed report on income structure by 20 July if annual income exceeded 30,000 MCI — KZT 129,750,000 in 2026.

17.    Obtain permits to engage foreign labour on ordinary terms and retain qualification documents for every foreign employee under article 7-1(4) of Law No. 207-V.

18.    Plan for the 1 January 2029 fork. On that date all tax reliefs expire and the export-orientation and 50 per cent state-income conditions switch on simultaneously.

Common Mistakes and What They Cost

Mistake 1. Assuming that registration on the register confers the tax reliefs. Registration is only the first of the three conditions of article 17 of the Tax Code. Cost: a company applies the zero rate for years without tracking the 90 per cent threshold and, on inspection, faces recalculation of CIT, individual income tax, social tax, VAT and withholding tax for the whole year of breach under article 739(4).

Mistake 2. Citing article 13-1 of the Law “On Informatization”. The article was excluded by Law No. 220-VIII of 27 September 2025. Cost: a contract, memorandum or opinion built on a repealed provision loses its legal foundation; in a dispute, a citation to a non-existent article undermines the whole position.

Mistake 3. Planning the 2027 cycle on the paragraph 33 text of 31 December 2025. The KZT 100,000,000 threshold and the 1 July deadline applied for the last time in the 2026 cycle; Order No. 421/НҚ of 17 July 2026 restated the paragraph, and from the 2027 cycle onwards the threshold is 30,000 MCI and the deadline 20 July. Cost: commissioning a full audit of financial statements instead of a report on income structure means paying a multiple of the fee for a document that does not answer the question paragraph 33 asks.

Mistake 4. Not tracking the non-core income share during the year. The 90 per cent threshold is measured against aggregate annual income and is finally known only after year end. Cost: one large non-core contract in December wipes out the relief for all twelve months, including salaries already paid without withholding individual income tax.

Mistake 5. Stating ambitious figures in the business plan. Paragraph 10 of Rules No. 599/НҚ makes a shortfall of more than 50 per cent against the business plan a ground for refusal. Cost: refusal of confirmation of entitlement to the zero CIT with every other condition satisfied — the relief is lost because of an optimistic forecast, not because of a breach.

Mistake 6. Ignoring the paragraph 31-1 counter-obligations. Their scope is set by the Fund’s internal documents rather than by the Rules, and a participant may simply never learn of them. Cost: subparagraph 7) of paragraph 28 — early termination by decision of the Commission, and with it the loss of condition 1) of article 17 and of all reliefs from the start of the tax period.

Mistake 7. Assuming membership gives an exemption from the foreign labour permit. The exemption is granted to AIFC participants, not to Astana Hub. Cost: administrative liability of the employer for engaging a foreign employee without a permit, plus the collapse of the relocation timetable.

Mistake 8. Expecting an exemption for dividends paid to a non-resident. Article 681 of the Tax Code contains no such subparagraph. Cost: failure to withhold on payment, with assessment and penalties — and all the more likely because the zero CIT at company level creates a false impression that the structure is tax-free throughout.

Mistake 9. Building a services model on article 741 without reading paragraph 1 of that article. Paragraph 1 contains only four items. Cost: applying the five conditions of paragraph 2 to income that does not fall within article 741 at all — and, consequently, either going through the Order No. 599/НҚ procedure needlessly or skipping it where it is mandatory.

Mistake 10. Keeping substantial development outsourced to a related foreign company. The nexus coefficient in article 740 reduces the share of intellectual property income reaching the reduction. Cost: income planned as wholly untaxed is taxed at 20 per cent.

Mistake 11. Not asking for the membership fee before registering. It is set by an internal normative document of the Fund and does not appear in the Rules. Cost: an unbudgeted cost line whose non-payment is a ground for early termination under paragraph 28(6).

Mistake 12. Planning a structure beyond 2029 without the fork. On 1 January 2029 the tax reliefs expire and the admission conditions tighten. Cost: a holding or licensing structure whose economics rest on a zero CIT after 2029 must be rebuilt at the moment when alternatives will be most expensive.

Mistake 13. Combining Astana Hub with another 100 per cent CIT reduction. Paragraph 5 of article 739 prohibits it expressly, and subparagraphs 3) and 5) of paragraph 7 of the Rules and article 283-1 of the Entrepreneurial Code close the question from both sides. Cost: refusal of both reliefs and recalculation of the tax.

Mistake 15. Building the payroll model on the assumption that “there are no payroll charges”. Of five charges the regime removes individual income tax entirely and medical insurance deductions and contributions entirely, while social tax falls away only for employees who are not citizens of the Republic of Kazakhstan. Social deductions and obligatory pension contributions are payable in the ordinary way. Cost: for a team of Kazakh specialists the real payroll saving is materially smaller than modelled, and the gap surfaces only after hiring.

Mistake 14. Treating the paragraph 33 report as confirmation of entitlement to the relief. These are three separate procedures with different recipients and deadlines. Cost: the company files the report by 20 July, misses the 1 February application under Rules No. 599/НҚ, and loses confirmation of entitlement to the CIT reduction on services income.

Who the Regime Suits, Who It Does Not, and When to Take Advice

It suits:

•          companies deriving at least 90 per cent of aggregate annual income from activities on the List approved by Order No. 521/НҚ;

•          product companies — developers of their own software, games, platforms and AI-based solutions: their income runs through article 740 or article 739(1)(3), bypassing the five conditions of article 741;

•          companies with a substantial payroll: the individual income tax relief under article 429(3) carries no threshold and no restriction, and medical insurance deductions and contributions fall away — though social tax remains payable on Kazakh-citizen employees, and social deductions and obligatory pension contributions are payable in the ordinary way;

•          companies doing their development inside Kazakhstan: the nexus coefficient in article 740 rewards in-house cost and penalises outsourcing to related foreign parties;

•          exporters — from 1 January 2029 export orientation becomes an admission condition, and those who already have it are ready for the fork;

•          companies with a planning horizon to 2029, for whom a review of the regime at that point is acceptable.

It does not suit:

•          companies working predominantly on public contracts: state bodies’ information systems are excluded from item 2 of the List, and from 2029 the 50 per cent cap under paragraph 7(9) of the Rules switches on as well;

•          subsoil users, special economic zone participants and holders of investment priority projects — the express prohibitions of paragraph 7(3) and 7(5) of the Rules;

•          companies with state participation of 50 per cent or more;

•          companies with a substantial share of non-core revenue: hardware resale, consulting outside the List, rent;

•          operators and contractors of gambling businesses — paragraph 7(10) of the Rules;

•          data centres serving digital mining — the express exclusion in item 19 of the List;

•          anyone counting on an exemption from the foreign labour permit or on an exemption for dividends to a non-resident: the regime gives neither.

Professional review is essential:

•          before the business plan is drafted — it governs both admission and the annual benchmark with its 50 per cent shortfall threshold;

•          where the income mix sits close to 90 per cent — computing the numerator requires the second part of paragraph 1 of article 17;

•          where development is outsourced to related parties — computing the nexus coefficient under article 740;

•          for a services model — compliance with subparagraphs 3), 4) and 5) of article 741(2) is established in a manner determined by the ministry;

•          for payments to non-residents — subparagraphs 11) and 13) of article 681 have closed lists and a carve-out for preferential-tax jurisdictions;

•          when planning relocation of foreign staff — the permit regime applies in full.

Frequently Asked Questions

Is an audit mandatory for Astana Hub participants in 2026? An audit of financial statements is not mandatory. Paragraph 33 of the Rules approved by Order No. 703/НҚ, as restated by Order No. 421/НҚ of 17 July 2026, requires participants with annual income above 30,000 MCI to submit annually, by 20 July, a report and/or conclusion on the structure of income and the compliance of activity with the List of priority activities, the data in which is confirmed by an auditor under the Law “On Auditing Activity”.

What income level triggers the mandatory report? Income exceeding thirty-thousand times the monthly calculation index. At an MCI of KZT 4,325 for 2026 that is KZT 129,750,000. The previous version of paragraph 33 set a fixed threshold of KZT 100,000,000 and a 1 July deadline. Because Order No. 421/НҚ was registered on 20 July 2026 and takes effect ten calendar days after publication, the 2026 reporting cycle ran on the old rule, and the new threshold and deadline apply for the first time in 2027.

What does participation in Astana Hub cost? The Rules impose no state registration fee. A participant pays membership fees on income for the preceding quarter, by the 25th day of the month following the expired quarter. The amount is set by an internal normative document of the Fund and is not published in any normative legal act — it should be requested from the Fund directly.

Does Astana Hub provide VAT relief? Yes, on three bases in the Tax Code: turnover on the sale of goods — article 474(33); turnover on the sale of works and services — article 474(34); and imports — article 479(1)(11), subject to four cumulative conditions. In addition, the acquisition of works and services from a non-resident is not treated as a taxable acquisition turnover — article 454(3)(3).

Do employees of an Astana Hub participant pay income tax? No. Subparagraph 3) of article 429 of the Tax Code reduces an employee’s income taxable at source by the income of employees of legal entities that are Astana Hub participants. The provision carries no monetary threshold and no citizenship restriction. But that holds for individual income tax only. Social tax remains payable on the income of employees who are citizens of the Republic of Kazakhstan, under the third sub-clause of subparagraph 3) of paragraph 2 of article 556. Social deductions under paragraph 1 of article 245 of the Social Code and obligatory pension contributions under paragraph 7 of the Rules approved by Government Resolution No. 525 of 30 June 2023 are payable in the ordinary way, because both provisions name subparagraph 3) of article 429 in their “with the exception of” clause. Only medical insurance deductions and contributions fall away: paragraph 1 of article 29 of Law No. 405-V names subparagraphs 2) and 4) of article 429 alone.

Until what year do the Astana Hub reliefs run? Until 1 January 2029. The sunset is set by subparagraph 3) of paragraph 2 of article 848 of the Tax Code, which names article 17, the whole of Chapter 82, and every associated provision on individual income tax, VAT, social tax and payments to non-residents.

What happens if the core-activity share falls below 90 per cent? Paragraph 4 of article 739 of the Tax Code: the taxpayer applies the generally established taxation regime from the date of the start of the tax period in which the breach was committed. The whole year is recomputed, but prior closed years are not reopened.

Can a participant hire foreign nationals without a permit? No. Government Resolution No. 1041 of 24 November 2023 does not include Astana Hub participants in the list of persons for whom no permit is required. The exemption is granted to participants of the Astana International Financial Centre, not to Astana Hub participants. Article 7-1 of Law No. 207-V provides visa advantages — an entry visa of up to five years for employees and family members and extension without leaving the country — but not an exemption from the permit.

How many activities are on the priority list? Nineteen. The List was approved by Order No. 521/НҚ of 20 October 2025, registered with the Ministry of Justice on 21 October 2025 under No. 37182 and in force from 1 January 2026. As at August 2026 it has not been amended.

Can Astana Hub be combined with a special economic zone or with investment preferences? No. Paragraph 7(5) of the Rules bars the registration of a special economic zone participant, and paragraph 7(3) bars the holder of an investment priority project. Paragraph 5 of article 739 of the Tax Code prohibits applying any other provision of the Code granting a 100 per cent CIT reduction. Subparagraph 3) of paragraph 4 of article 283-1 of the Entrepreneurial Code excludes Astana Hub participants from investment preferences.

What are a participant’s counter-obligations? The obligation introduced by paragraph 31-1 of the Rules to contribute to the development of the IT ecosystem along seven directions, from disseminating knowledge to promoting employment. The volume is determined on a differentiated basis, taking account of headcount and the volume of financial and economic activity, by the Fund’s internal normative documents, and performance is recorded through the Fund’s web resource. Failure is a ground for early termination under paragraph 28(7).

Is article 13-1 of the Law “On Informatization” still in force? No. Article 13-1, “International Technology Park ‘Astana Hub’”, was excluded by Law No. 220-VIII of 27 September 2025. The framing statute is Law No. 207-V of 10 June 2014, whose title was restated by the same law as “On the Innovation Cluster ‘Astana Hub’”.

Key Takeaways

•          The Rules of activity were approved by Order No. 703/НҚ of 31 December 2025 (MoJ No. 37807 of 5 January 2026), operate from 23 January 2026, were amended by Order No. 421/НҚ of 17 July 2026, and repealed five earlier orders including Order No. 415 of 26 September 2018.

•          Article 13-1 of the Law “On Informatization” has been excluded; the framing statute is No. 207-V of 10 June 2014 as retitled by Law No. 220-VIII.

•          There is no mandatory audit of financial statements. Paragraph 33 requires a report and/or conclusion on income structure, confirmed by an auditor, for income above 30,000 MCI, by 20 July. The new text applies for the first time to the 2027 cycle: Order No. 421/НҚ was registered on 20 July 2026 (MoJ No. 39352) and took effect after both of the 2026 reporting dates.

•          The principal novelty of 2026 is paragraph 31-1: counter-obligations to develop the IT ecosystem, scoped by the Fund’s internal documents, with a direct sanction under paragraph 28(7).

•          There are ten admission conditions, but subparagraphs 8) and 9) of paragraph 7 — export orientation and the 50 per cent cap on state income — take effect only from 1 January 2029.

•          The List of priority activities runs to nineteen items, Order No. 521/НҚ of 20 October 2025, unamended during 2026.

•          The tax threshold is 90 per cent of aggregate annual income — article 17 of Tax Code No. 214-VIII.

•          The reliefs are in Chapter 82 (articles 738 to 741): a 100 per cent CIT reduction, relief from individual income tax for employees (article 429(3)), exclusion from the social tax object for employees who are not Kazakh citizens only (third sub-clause of article 556(2)(3)), reduction of taxable income by the gain on the sale of shares and interests (article 337(2), first part, subparagraph 10)), three VAT reliefs (articles 474, 479, 454), and exemption for service payments (article 681(11)) and royalties (article 681(13)) to non-residents.

•          Dividends to non-residents are not exempt.

•          Three income streams — intellectual property (article 740, nexus coefficient), four service items (article 741, five conditions), and other income (article 739(1)(3), unconditional).

•          Entitlement on services income is confirmed separately — Rules under Order No. 599/НҚ, application by 1 February, refusal where actual figures fall short of the business plan by more than 50 per cent.

•          Breach of article 17 triggers recalculation from the start of the tax period — article 739(4).

•          The reliefs run to 1 January 2029 — article 848(2)(3).

•          There is no exemption from the foreign labour permit; there is a visa of up to five years under article 7-1 of Law No. 207-V.

Summary 

Astana Hub in 2026 is governed by the Rules of Activity of the Autonomous Cluster Fund “Astana Hub”, approved by Order of the Deputy Prime Minister — Minister of Artificial Intelligence and Digital Development No. 703/НҚ of 31 December 2025 (registered with the Ministry of Justice on 5 January 2026 under No. 37807, in force from 23 January 2026 except subparagraphs 8) and 9) of paragraph 7, which take effect on 1 January 2029), as amended by Order No. 421/НҚ of 17 July 2026; the framing statute is Law of the Republic of Kazakhstan No. 207-V of 10 June 2014 “On the Innovation Cluster ‘Astana Hub’”, and article 13-1 of the Law “On Informatization” was excluded by Law No. 220-VIII of 27 September 2025. Participants are not subject to a mandatory audit of financial statements: paragraph 33 of the Rules requires participants with annual income above 30,000 MCI — KZT 129,750,000 at an MCI of KZT 4,325 for 2026 — to submit annually by 20 July a report and/or conclusion on the structure of income and the compliance of activity with the List of priority ICT activities, the data in which is confirmed by an auditor under the Law “On Auditing Activity”; the previous text required an audit to be conducted where income exceeded KZT 100,000,000, by 1 July, and because the amending order was registered with the Ministry of Justice on 20 July 2026 under No. 39352 and takes effect ten calendar days after first official publication, the 2026 reporting cycle ran on the previous text and the new one applies for the first time in 2027. The same order introduced paragraph 31-1 on counter-obligations to develop the IT ecosystem, scoped by the Fund’s internal normative documents, non-performance of which is a ground for early termination of participation under paragraph 28(7). Registration requires compliance with the ten conditions of paragraph 7 of the Rules; the Selection Commission decides within 10 working days after a 15-working-day review by the Fund, and there are only two grounds for refusal. The List of priority activities contains nineteen items and was approved by Order No. 521/НҚ of 20 October 2025 (MoJ No. 37182), unamended during 2026. The tax reliefs sit in Chapter 82 of Tax Code No. 214-VIII (articles 738 to 741) for persons meeting article 17: registration with the Fund, not less than 90 per cent of aggregate annual income from priority activities, and compliance of goods with the own-production criteria. The reliefs comprise a 100 per cent reduction of computed corporate income tax, reduction of employees’ income for individual income tax under article 429(3), exclusion of that income from the social tax object under article 556(2)(3) — but only as regards employees who are not citizens of the Republic of Kazakhstan, because the third sub-clause of that subparagraph keeps the income of Kazakh citizens inside the object, reduction of taxable income by the gain on the sale of a participant’s shares and participation interests under subparagraph 10) of the first part of article 337(2), VAT exemptions under article 474(33) and (34) and article 479(1)(11), reverse-charge VAT relief under article 454(3)(3), and exemption for payments to non-residents under article 681(11) and (13); dividends to non-residents are not exempt. Entitlement to the CIT reduction on informatization services income is confirmed under the Rules approved by Order No. 599/НҚ of 27 November 2025 — application by 1 February, review within 25 calendar days, refusal where actual figures fall short of the business plan by more than 50 per cent. Where article 17 is breached, the generally established taxation regime applies from the date of the start of the tax period in which the breach occurred (article 739(4)). The regime does not remove payroll charges in full: social deductions under paragraph 1 of article 245 of the Social Code and obligatory pension contributions under paragraph 7 of the Rules approved by Government Resolution No. 525 of 30 June 2023 remain payable in the ordinary way, because both name subparagraph 3) of article 429, while medical insurance deductions and contributions fall away because paragraph 1 of article 29 of Law No. 405-V names only subparagraphs 2) and 4) of article 429. All the reliefs run until 1 January 2029 under subparagraph 3) of paragraph 2 of article 848 of the Tax Code. Membership confers no exemption from the permit to engage foreign labour — that exemption belongs to AIFC participants under Government Resolution No. 1041 of 24 November 2023; article 7-1 of Law No. 207-V grants employees and their family members an entry visa valid for up to five years, extendable without leaving the country.

Planning to join Astana Hub, or already a participant and want your income structure checked? UPPERSETUP can match your activity against the List of priority activities, compute the 90 per cent threshold under article 17 of the Tax Code including every category that counts towards it, assess the nexus coefficient where development is outsourced, and draft the business plan so that it does not become a benchmark used against you. Choose your jurisdiction inside Kazakhstan with UPPERSETUP.

Sources

Laws of the Republic of Kazakhstan

1.        Law No. 207-V of 10 June 2014 “On the Innovation Cluster ‘Astana Hub’” — consolidated text as amended to 12.07.2026, mirror zakon.uchet.kz

2.        Law No. 207-V of 10 June 2014 — mirror prg.kz

3.        Law No. 220-VIII of 27 September 2025 amending legislative acts on state support of innovation activity and state statistics — mirror prg.kz

4.        Law No. 220-VIII of 27 September 2025 — mirror zakon.uchet.kz

5.        Law No. 418-V of 24 November 2015 “On Informatization” — text in force, mirror zakon.uchet.kz

6.        Repeal note for article 13-1 of the Law “On Informatization” — mirror kodeksy-kz.com

7.        Law No. 405-V of 16 November 2015 “On Compulsory Social Medical Insurance”, article 29 — mirror kodeksy-kz.com, text verified 30.07.2026

8.        Law No. 405-V “On Compulsory Social Medical Insurance”, article 29 — second independent mirror zakon.mybuh.kz

9.        Law No. 167-VI of 2 July 2018 “On Currency Regulation and Currency Control” — mirror kodeksy-kz.com

10.    Constitutional Law No. 438-V of 7 December 2015 “On the Astana International Financial Centre” — mirror zakon.uchet.kz

11.    Constitutional Law No. 438-V — consolidated text published by the AIFC Court in December 2025

12.    Law No. 477-IV of 22 July 2011 “On Population Migration” — adilet.zan.kz

13.    Law No. 239-VIII of 8 December 2025 “On the Republican Budget for 2026–2028” — subparagraph 4) of article 7 sets the MCI at KZT 4,325 from 1 January 2026, mirror prg.kz

14.    Law No. 239-VIII of 8 December 2025 — mirror zakon.uchet.kz

15.    Law No. 215-VIII of 18 July 2025 amending legislative acts on taxation — mirror zakon.uchet.kz

Codes of the Republic of Kazakhstan

16.    Code No. 214-VIII of 18 July 2025 (Tax Code), article 17 “Astana Hub Participant” — mirror pavlodar.com

17.    Tax Code, article 400 “General provisions on the reduction of taxable income” — mirror pavlodar.com

18.    Tax Code, article 337 “Reduction of taxable income” — subparagraph 10) of the first part of paragraph 2 on shares and interests of Astana Hub participants, mirror pavlodar.com

19.    Tax Code, article 337 — mirror kodeksy-kz.com

20.    Tax Code, article 343 “Loss on an intellectual property object in priority activities of Astana Hub participants” — mirror kodeksy-kz.com

21.    Tax Code, article 345 “Computation of the amount of corporate income tax” — mirror kodeksy-kz.com

22.    Tax Code, article 429 “Reduction of an employee’s income taxable at source of payment” — mirror pavlodar.com

23.    Tax Code, article 454 — reverse-charge VAT — mirror pavlodar.com

24.    Tax Code, article 474 — turnover exempt from VAT — mirror pavlodar.com

25.    Tax Code, article 479 — imports exempt from VAT — mirror pavlodar.com

26.    Tax Code, article 556 — object of social tax — mirror pavlodar.com

27.    Tax Code, article 556 — second independent mirror kodeksy-kz.com

28.    Tax Code, article 681 “Income of a non-resident not subject to taxation in the Republic of Kazakhstan” — mirror pavlodar.com

29.    Tax Code, article 681 — mirror kodeksy-kz.com

30.    Tax Code, article 738 “Taxation of Astana Hub participants” — mirror pavlodar.com

31.    Tax Code, article 739 “General provisions” — mirror pavlodar.com

32.    Tax Code, article 739 — mirror kodeksy-kz.com

33.    Tax Code, article 740 — CIT reduction on intellectual property income and the nexus coefficient — mirror pavlodar.com

34.    Tax Code, article 741 — CIT reduction on income from informatization services — mirror pavlodar.com

35.    Tax Code, article 848 “Procedure for the entry into force of this Code” — mirror pavlodar.com

36.    Chapter 82 “Tax preferences of Astana Hub participants” — contents of Section 17, mirror pavlodar.com

37.    Social Code No. 224-VII of 20 April 2023, article 245 “Object for calculating social deductions” — mirror pavlodar.com

38.    Repealed Code No. 120-VI of 25 December 2017 — repeal details, mirror online.zakon.kz

39.    Entrepreneurial Code, article 283-1 — exclusion of Astana Hub participants from investment preferences, mirror kodeksy-kz.com

Orders of the authorised body

40.    Order of the Deputy Prime Minister — Minister of Artificial Intelligence and Digital Development No. 703/НҚ of 31 December 2025 approving the Rules of Activity of the Autonomous Cluster Fund “Astana Hub”, MoJ No. 37807 of 05.01.2026, consolidated text as amended to 17.07.2026 — mirror zakon.uchet.kz

41.    Order No. 703/НҚ — mirror zakon.mybuh.kz, carrying the Ministry of Justice registration line

42.    Order No. 703/НҚ — mirror prg.kz

43.    Order of the acting Minister of Artificial Intelligence and Digital Development No. 421/НҚ of 17 July 2026 amending Order No. 703/НҚ, MoJ No. 39352 of 20.07.2026 — mirror zakon.uchet.kz

44.    The original text of Rules No. 703/НҚ as at 31 December 2025 — mirror zakon.mybuh.kz

45.    Repealed Order of the Minister of Information and Communications No. 415 of 26 September 2018, MoJ No. 17437 — mirror zakon.uchet.kz

46.    Order No. 521/НҚ of 20 October 2025 approving the List of priority ICT activities and the own-production criterion, MoJ No. 37182 of 21.10.2025 — mirror zakon.mybuh.kz

47.    Order No. 521/НҚ — mirror zakon.uchet.kz

48.    Order No. 521/НҚ — adilet.zan.kz

49.    Order No. 599/НҚ of 27 November 2025 approving the Rules for establishing the compliance of an Astana Hub participant with the conditions for a 100 per cent CIT reduction on income from informatization services, MoJ No. 37492 of 28.11.2025 — mirror zakon.mybuh.kz

50.    Order No. 599/НҚ — mirror zakon.uchet.kz

51.    Order of the acting Minister of Digital Development No. 250/НҚ of 12 July 2023 designating the international technology park “Astana Hub” — mirror zakon.uchet.kz

Government resolutions 52. Government Resolution No. 525 of 30 June 2023 approving the Rules and time limits for computing, withholding and transferring obligatory pension contributions and obligatory professional pension contributions to the Unified Accumulative Pension Fund — mirror zakon.mybuh.kz 53. Government Resolution No. 540 of 3 July 2023 approving the Rules and time limits for computing and transferring employer obligatory pension contributions — mirror zakon.mybuh.kz 54. Government Resolution No. 939 of 7 November 2025 amending certain decisions of the Government of the Republic of Kazakhstan — in force from 1 January 2026, mirror zakon.uchet.kz

55.    Government Resolution No. 1041 of 24 November 2023 determining the list of persons for whom permits of local executive bodies to engage foreign labour are not required — mirror zakon.uchet.kz

56.    Resolution No. 1041 — mirror zakon.mybuh.kz

57.    Resolution No. 1041 — adilet.zan.kz

Official resources

58.    Autonomous Cluster Fund “Astana Hub” — official website

59.    Astana Hub notice of the new participant requirement, 22 January 2026 (describing the text of paragraph 33 in force until 17 July 2026)

60.    Ministry of Artificial Intelligence and Digital Development of the Republic of Kazakhstan

61.    State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan

A note on sources and levels of confirmation. The official legal portal adilet.zan.kz is closed to automated retrieval, so every normative text has been checked against consolidated versions on the mirrors named individually above; the mirror is identified for each group of provisions. The load-bearing provisions — paragraphs 7, 12 to 19, 21 to 33, 31-1 and 37 to 40 of Rules No. 703/НҚ; articles 17, 337, 343, 345, 400, 429, 454, 474, 479, 556, 681, 738 to 741 and 848 of the Tax Code; article 245 of the Social Code; article 29 of Law No. 405-V; paragraph 7 of the Rules approved by Government Resolution No. 525; and articles 7 and 7-1 of Law No. 207-V — were read directly from the consolidated texts. The provisions on which the social tax and payroll conclusions depend — subparagraph 3) of paragraph 2 of article 556, paragraph 1 of article 245 of the Social Code and paragraph 1 of article 29 of Law No. 405-V — were each checked against at least two independent mirrors, which agree word for word. Order No. 421/НҚ of 17 July 2026 was registered with the Ministry of Justice of the Republic of Kazakhstan on 20 July 2026 under No. 39352; the registration details were established from the text of the order on the zakon.uchet.kz mirror (document identifier V2600039352). The comparison between the version in force and the original version of the Rules was made against the zakon.mybuh.kz mirror, which preserves the redaction of 31 December 2025. Publications from the first half of 2026, including Astana Hub’s own notice of 22 January 2026, describe the version of paragraph 33 in force until 17 July 2026 and cannot be used as a source for the requirements now in force; the link is given solely to illustrate the divergence between the two texts.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before acting on any of it, obtain individual professional advice reflecting your specific circumstances, jurisdiction, corporate status and the regulators’ current requirements.

Position stated as at: August 2026.