Corporate Income Tax in Kazakhstan in 2026: Which Rate Applies to Your Company, What Actually Qualifies as a Deduction, and How to File Form 100.00 Without Additional Assessments

Corporate income tax (CIT) is the tax on the profits of Kazakhstan legal entities, computed from 1 January 2026 under the new Tax Code: the standard rate is 20 per cent, the rate for second-tier banks and gambling operators is 25 per cent, the rate for social-sphere organisations is 5 per cent in 2026 and 10 per cent from 2027, and the rate for agricultural producers is 3 per cent. The return is filed on form 100.00 by 31 March, the tax is paid within ten calendar days after that deadline, and a loss is carried forward for ten years.

Important. Form 100.00 for 2026 was approved by Order of the Minister of Finance of the Republic of Kazakhstan No. 695 of 12 November 2025 and is structured so that the return itself contains only two computational lines, and the entire tax computation has been moved into appendix 100.01, which is completed separately for each type of activity carrying its own rate. A company with income from both ordinary and concessionary activities files several forms 100.01 inside a single return.

The legal basis: which code applies in 2026 and what exactly has changed

The legal basis of corporate income tax in Kazakhstan in 2026 is Section 5 of the Tax Code of the Republic of Kazakhstan, enacted as Code of the Republic of Kazakhstan No. 214-VIII ZRK of 18 July 2025.

The date the code was issued and the date it entered into force are different, and that difference matters. Code of the Republic of Kazakhstan No. 214-VIII ZRK was issued on 18 July 2025 and entered into force on 1 January 2026 — this is stated directly in paragraph 1 of article 848 of the code. The exceptions are narrow: article 189 entered into force on 1 July 2026, and article 92 together with chapter 90 will enter into force on 1 January 2027.

The previous code ceased to apply on the same date. Paragraph 3 of article 848 repealed the Code of the Republic of Kazakhstan of 25 December 2017 “On Taxes and Other Obligatory Payments to the Budget” from the date the code 214-VIII entered into force, that is from 1 January 2026. Only two trailing provisions survived: paragraph 1-1 of article 68 of the former code is repealed from 1 January 2027, and paragraph 23 of article 26 from 1 January 2029. The practical conclusion is simple: for the 2026 tax period and onwards CIT is computed exclusively under code 214-VIII, and references to articles of the former code in accounting policies, tax-register templates and internal methodologies should be replaced.

The amendment chain of code 214-VIII itself is extremely short to date. As at 22 September 2026 the Tax Code of the Republic of Kazakhstan No. 214-VIII has been amended by a single act — Law of the Republic of Kazakhstan No. 308-VIII of 11 June 2026, which entered into force on 1 July 2026. That law touched neither the rates, nor the deductions, nor the deadlines: it made blanket terminological replacements throughout the text — the word “иностранец” (“foreigner”), in all its inflected forms, was replaced by “иностранный гражданин” (“foreign citizen”), the word “тенге” was respelled “теңге” in Kazakh orthography, and the wording on cities of republican significance and the capital was brought into a single, consistent word order. For the computation of CIT these amendments are neutral.

A separate layer that is often overlooked is the set of provisions with a limited period of effect. Paragraph 2 of article 848 sets the dates until which individual subparagraphs of the code apply, and for CIT this is material. The following apply until 1 January 2029, among others: article 17 of the code, subparagraph 17) of article 286, subparagraph 6) of paragraph 1 of article 348 exempting “Astana Hub” participants from advance payments, and part one of paragraph 3 of article 682. Subparagraph 15) of article 286 applies until 1 January 2028, subparagraph 13) of part one of paragraph 2 of article 337 and subparagraph 19) of paragraph 3 of article 351 until 1 January 2027, and subparagraphs 4) and 9) of part one and part three of paragraph 2 of article 337 until 1 January 2031. A company building a tax model over several years must take these dates into account: a relief that works in 2026 may disappear in 2029 without any separate repealing law.

The second mandatory element of the legal basis is the reporting form. The tax reporting forms for 2026 were approved by Order of the Minister of Finance of the Republic of Kazakhstan No. 695 of 12 November 2025 “On the approval of tax reporting forms with explanations for their completion and the Rules for their submission”, registered with the Ministry of Justice of the Republic of Kazakhstan on 12 November 2025 under No. 37390; paragraph 3 of the order brings it into force from 1 January 2026.The CIT return is appendix 2 to the order (form 100.00), and the calculation of advance payments after the return is appendix 3 (form 101.02). As at 22 September 2026 order No. 695 has not been amended.

The wider context of the tax reform of which CIT forms part is covered separately in Kazakhstan’s Tax System 2026: A Complete Breakdown — the New Tax Code, CIT, VAT, PIT, and AIFC Incentives.

Who pays corporate income tax and what exactly is taxed

A corporate income tax payer is a legal entity on which article 233 of the Tax Code imposes the obligation to compute and pay CIT for the tax period.

The class of payers is defined in two sentences. Paragraph 1 of article 233 treats as CIT payers legal entities that are residents of the Republic of Kazakhstan, as well as non-resident legal entities that carry on activity in the Republic of Kazakhstan through a permanent establishment or derive income from sources in the Republic of Kazakhstan. Paragraph 2 of the same article removes state institutions from the class of payers.

Taxpayers on special tax regimes form a separate category. Article 234 states that such taxpayers compute and pay CIT on income taxed within the regime in accordance with section 16 of the code. Paragraph 3 of article 359 expressly exempts a legal entity on the special tax regime based on a simplified declaration from filing form 100.00 in respect of income taxed within that regime, and paragraph 5 of article 358 excludes from the CIT tax period any time during which the taxpayer applied that regime exclusively. The choice between the general regime and a special regime is covered in Kazakhstan’s Special Tax Regimes 2026: Three Regimes Instead of Six, the Simplified Declaration, the Self-Employed Regime and the End of Retail Tax, and the choice of legal form for a foreign founder in LLP (TOO) in Kazakhstan for Foreigners 2026: Registration, Visa, Taxes, and AIFC Comparison. The full list of services for the jurisdiction is set out at Business Setup in Kazakhstan: Company Registration and Accounting Services.

The objects of taxation are listed in article 235 as a closed set of four: taxable income; income taxed at source of payment; the net income of a non-resident legal entity carrying on activity in the Republic of Kazakhstan through a permanent establishment; and the taxable income of controlled foreign companies and of permanent establishments of controlled foreign companies. These four objects are not alternatives: a single company may have several of them in one tax period, and each is computed under its own rules and its own rate.

That is precisely why a non-resident company with a permanent establishment in Kazakhstan pays CIT twice on different grounds. First the permanent establishment pays tax on taxable income at the general rate, and then it pays tax on net income. The corporate income tax rate on the net income of a non-resident legal entity carrying on activity in the Republic of Kazakhstan through a permanent establishment is 15 per cent (subparagraph 4) of paragraph 1 of article 357). A double tax treaty may reduce that rate, and form 100.01 contains dedicated lines for the country code and the name of the treaty.

Which rate applies to your company: 20, 25, 6, 5 or 3 per cent — and when the 10 per cent rate arrives

The corporate income tax rate is the percentage applied to taxable income in order to compute the tax; in Kazakhstan the rate depends not on the size of the company but on the type of its activity.

Article 357 is split into two levels. Paragraph 1 sets the rates by object of taxation, paragraph 2 the rates by type of activity applied to taxable income. Paragraph 3 clarifies that income from agricultural activity includes budget subsidies granted to producers of agricultural products.

The general corporate income tax rate in Kazakhstan in 2026 is 20 per cent and applies to all types of activity other than those expressly listed in subparagraphs 1)–4) of paragraph 2 of article 357.

The 25 per cent rate applies to two categories of income: income from the banking activity of second-tier banks, other than taxable income from lending to business entities, and income from the activity of casinos, slot-machine halls, totalisators and bookmakers. The carve-out for business lending is fundamental: the procedure for determining taxable income from the banking activity of second-tier banks is set jointly by the authorised body and the National Bank, while income in the form of interest and gains on state issue-grade securities issued by the National Bank is expressly treated by the code as banking activity and taxed at 25 per cent.

The rate for the social sphere deserves particular attention because it changes inside the planning horizon. For organisations carrying on activity in the social sphere (other than those applying article 330 of the code) the rate is 5 per cent for the tax period from 1 January 2026 to 31 December 2026, and 10 per cent from 1 January 2027. In other words, the “10 per cent” so often quoted in summaries does not yet apply in 2026: the current tax period carries a transitional rate of 5 per cent, and the doubling occurs on the very first day of 2027.

Agriculture is split between two rates. Income from the production of agricultural products and aquaculture (fish-farming) products, and from the processing of such products of a producer’s own production and the sale of the processed products, derived by legal entities that are producers, is taxed at 3 per cent. Income from the activity of agricultural cooperatives not falling within the preceding subparagraph is taxed at 6 per cent.

The rates for non-residents are set out in a separate article 682 and form their own scale. The general rate on income determined by article 679 is 20 per cent. Insurance premiums under risk insurance contracts are taxed at 15 per cent, under reinsurance contracts at 5 per cent, and income from international transportation services at 5 per cent. Gains, dividends, interest and royalties of a non-resident are taxed at source at 15 per cent, while interest on loans and debt securities is taxed at 10 per cent. Dividends paid to a person holding, directly or indirectly, at least twenty-five per cent of the capital of a Kazakhstan legal entity are taxed on a progressive scale: 5 per cent up to and including 230,000 times the monthly calculation index, and 15 per cent on the excess. Income of a person registered in a state with preferential taxation is taxed at source at 20 per cent regardless of the type of income (paragraph 2 of article 682).

How the tax is computed: the formula of article 236 and the mechanics of article 345

Taxable income is the positive result of the formula prescribed by the code, and a loss from entrepreneurial activity is the negative result of the same formula.

Paragraph 1 of article 236 states the formula literally: TI/L = AGI – R +(–) IA – D +(–) DA, where TI is taxable income when the result is positive, L is the loss from entrepreneurial activity when the result is negative, AGI is aggregate annual income, R is the reduction of aggregate annual income under article 255, IA is the income adjustment under article 256, D is deductions, and DA is the deduction adjustment under article 288.

That formula produces an intermediate figure, not the tax. Two further steps lie between taxable income and the tax base, and they are described in paragraph 2 of article 345. Taxable income for the purpose of computing the tax is determined as taxable income under article 236 minus the reduction of taxable income under article 337 minus the losses carried forward or compensated under articles 339–344. The rate applies only to that amount.

The computation of the tax itself is described in paragraph 1 of article 345 as a sequence of additions and subtractions. To the CIT computed on taxable income for each type of activity is added the CIT on the taxable income of controlled foreign companies and their permanent establishments; from that total are subtracted the foreign tax credit under article 346, the CIT withheld at source during the tax period under article 352 where supporting documents exist, and the CIT withheld at source and carried forward from previous tax periods.

The last element deserves separate mention because it is frequently lost. The positive difference between the amount of CIT withheld at source and the amount of computed CIT payable to the budget is carried forward to subsequent tax periods within the limitation period and successively reduces the tax payable in those periods (paragraph 4 of article 345). Excess tax withheld at source does not expire at the year end — it remains an asset of the company, but only if it has been reported in the return.

An important detail that determines the whole architecture of the reporting: paragraph 2 of article 345 requires CIT to be computed separately for each type of activity listed in paragraph 2 of article 357, as the product of taxable income for the purpose of computing the tax and the corresponding rate. A company that has both ordinary activity at 20 per cent and, say, social-sphere activity at 5 per cent keeps a separate computation and completes a separate form 100.01 for each activity marker.

Aggregate annual income: what enters the base and what is taken out of it

Aggregate annual income (AGI) is the sum of all types of income receivable or received by a taxpayer during the tax period, excluding value added tax and excise duty.

Paragraph 1 of article 237 defines the territorial scope: the aggregate annual income of a resident legal entity consists of income from sources in the Republic of Kazakhstan and from sources outside the Republic of Kazakhstan, and income from foreign sources means all types of income that are not income from sources in Kazakhstan, irrespective of the place of payment. The aggregate annual income of a non-resident acting through a permanent establishment is determined under article 688.

Paragraph 2 of article 237 lists thirty-one types of income included in aggregate annual income. The list covers income from sales, gains, income from doubtful liabilities, income from the write-off of liabilities, income from the assignment of a claim, income from the disposal of fixed assets, income from joint activity, penalties awarded or acknowledged by a debtor, compensation received, income in the form of property received free of charge, dividends, interest on deposits and debt securities, the excess of positive over negative exchange differences, winnings, income from the sale of an enterprise as a property complex, income on derivatives and insurance contracts, and three positions relating to digital assets — the income of a person carrying on digital mining, the income of a digital mining pool and the income of a digital asset exchange. Subparagraph 31) closes the list with “other income”, which makes the list open-ended.

The rule on recognition refers to accounting, but with an important caveat. Paragraph 3 of article 237 provides that the recognition of income, including the date of recognition, follows international financial reporting standards and the requirements of accounting legislation; however, where the accounting treatment differs from the tax treatment, income is accounted for in the manner prescribed by the code. The same paragraph records the single-count principle: where the same income may be reflected under several income headings, it is included in AGI once.

Two different figures are taken out of aggregate annual income, and they should not be confused. The reduction of aggregate annual income under article 255 removes specific income from the base: dividends (other than those received by a non-resident’s permanent establishment and failing the conditions of subparagraph 7) of article 681); income of a person carrying on digital mining from the sale of digital assets; net income from the trust management of property in the hands of the founder of the trust management (the settlor); income of a non-commercial organisation under paragraph 1 of article 329; and the value of services received out of budget funds as state non-financial support for business. The adjustment of income under article 256 changes the amount of income previously recognised in four cases: a full or partial return of goods, a change in the terms of a transaction, a change in the price or compensation for goods, work and services sold, and a price discount or sales discount. The adjustment is made in the tax period in which the relevant event occurred.

Article 238 adds a third layer — economic benefits that are not treated as income at all. These include the value of property received as a contribution to charter capital and an additional contribution by a participant to the property of a legal entity; the value of property received by an issuer from the placement of its shares; the value of property transferred free of charge, in the hands of the transferor; the amount of written-off tax debt; and the amount by which a tax liability is reduced in cases provided for by the code. The value of goods received free of charge for advertising purposes is not treated as income if the value of one unit of such goods does not exceed 5 times the monthly calculation index (MCI) in force on the date of receipt.

Exchange differences and revaluations call for particular care. Subparagraph 8) of paragraph 1 of article 238 removes from income the accounting gain arising on a change in the value of assets and liabilities, other than an amount receivable from another person. A mirror rule applies to expenses: paragraph 6 of article 257 does not treat as costs for tax purposes the costs arising in accounting from a change in the value of assets and liabilities, other than amounts payable.

Deductions: the general rule, documentary support and the single-count principle

A deduction is an expense of a taxpayer connected with carrying on activity directed at deriving income, which reduces aggregate annual income in determining taxable income.

Paragraph 1 of article 257 states the general rule: expenses of a taxpayer connected with carrying on activity directed at deriving income are deductible subject to article 257, articles 258–273 and chapters 27–31 of the code, other than costs that are not deductible. There is no territorial limitation — the rule applies to expenses incurred both in Kazakhstan and outside it.

Three procedural requirements determine whether a deduction survives an audit. Paragraph 4 of article 257: deductions are made on the basis of expenses actually incurred, where documents supporting those expenses and their connection with activity directed at deriving income exist. Paragraph 3: deferred expenses are deductible in the tax period to which they relate. Paragraph 8: where the same types of expense are provided for under several expense headings, they are deducted only once in computing taxable income.

The relationship between accounting and tax treatment mirrors the rule for income. Paragraph 5 of article 257 refers to international financial reporting standards, but where the timing or manner of recognition differs, the expenses are accounted for in the manner prescribed by the code. The practical consequence is that tax registers for deductions must show the bridge from the accounting figure to the tax figure rather than reproducing the trial balance. Setting up that accounting and maintaining the tax registers are covered by UPPERSETUP accounting support. The requirements applying to the financial statements themselves and to statutory audit are covered in Mandatory audit and financial reporting in Kazakhstan in 2026: who, what and by when.

The code deals separately with the expenses of a resident’s foreign permanent establishment. Paragraph 9 of article 257 permits the deduction of management and general administrative expenses incurred both in Kazakhstan and abroad for the purpose of deriving the taxable income of that permanent establishment, in accordance with the tax legislation of the foreign state or a double tax treaty. Where the foreign legislation permits the deduction but does not prescribe the allocation method, the resident applies articles 708–711 of the code. Form 100.00 provides appendix 100.03 for this computation.

Finally, deductions are adjusted on the same four grounds as income. Article 288 defines the adjustment of deductions as an increase or decrease in the deductions of the reporting period within the limits of the deduction previously recognised, on a return of goods, a change in the terms of a transaction, a change in the price or compensation, and discounts. Paragraph 10 of article 257 allows the amount of deductions after adjustment to be negative.

Capped deductions: one per cent, three per cent and the limiting coefficient

A capped deduction is an expense taken not in full but within a limit set by the code; the excess over the maximum deductible amount is not deductible by virtue of subparagraph 4) of article 286.

The first cap applies to hospitality. Representation expenses are deductible in an amount not exceeding 1 per cent of the employer’s expenses on employee income subject to taxation as specified in subparagraph 1) of article 426 of the code for the tax period (paragraph 3 of article 262). The base of the cap is the employer’s expenses on employee income rather than revenue, so for a company with a small headcount the limit turns out to be minuscule.

The composition of representation expenses is defined exhaustively. Paragraph 1 of article 262 covers expenses on receiving individuals, including those not on the taxpayer’s staff, at events held to establish or maintain mutual cooperation and at meetings of the board of directors or another management body other than executive bodies — irrespective of the venue. They include transport for participants, catering during the event, the services of interpreters not on the staff, and the rental and decoration of premises. Paragraph 4 of article 262 expressly excludes from representation expenses, and from deductions altogether, the costs of rail, sea and air transport for invited persons, their accommodation, visa processing, and the organisation of leisure, entertainment and recreation.

The documentary package for representation expenses is listed in paragraph 2 of article 262 and consists of four items: an order or instruction to hold the event stating its purpose and the persons responsible; an approved budget of expenses; a report by the responsible persons stating the date, venue, results, list of participants, programme and expenses actually incurred; and primary and other supporting documents. The code requires all four documents together.

The second cap restricts the deduction of interest. The deduction of interest is limited to the amount computed under the formula (A + E) + (EQ/LB) × (LC) × (B + C + D) (paragraph 4 of article 263), where A is interest other than that included in B, C, D and E; B is interest paid to a related party; C is interest paid to persons registered in a state with preferential taxation; D is interest paid to an independent party on loans secured by a related party’s deposit or guarantee; E is interest on loans from a credit partnership and from the bank that is the national development institution, and the discount or coupon on debt securities held by the unified accumulative pension fund; EQ is the average annual amount of equity capital; LB is the average annual amount of liabilities; and LC is the limiting coefficient.

The limiting coefficient equals 7 for financial organisations, other than organisations carrying on microfinance activity, and 4 for other legal entities, including microfinance organisations (subparagraph 3) of paragraph 5 of article 263). The same paragraph 5 also sets out how the components are measured: the average annual amount of equity capital is the arithmetic mean of equity at the end of each month of the reporting period, with a negative value treated as zero; the average annual amount of liabilities is the arithmetic mean of the maximum liabilities in each month, and liabilities for taxes and budget payments, wages and other employee income, deferred income (other than from a related party), interest and commission, dividends and estimated provisions are excluded from that measurement.

Paragraph 3 of article 263 puts part of the interest deduction on a cash basis: interest owed to second-tier banks (other than the bank that is the national development institution), to microfinance organisations other than pawnshops, and to persons who have acquired claims under loans is deductible in the amount actually paid.

The third cap is the one most often underestimated. Management, consultancy, consulting, audit, design, legal, accounting, advocate’s, advertising, marketing, franchising, financial (other than interest expenses), engineering and agency services, royalties and rights to use intellectual property acquired from a related party registered in a state with preferential taxation are deductible in a total amount not exceeding 3 per cent of the taxable income of the reporting tax period determined before the deduction of the expenses covered by article 264.

The design of this cap creates a circular dependency that has to be resolved iteratively: to compute the limit you need taxable income, and to arrive at taxable income you need the limit. In practice the computation is made in two passes — first taxable income is determined without the article 264 expenses, then 3 per cent of that figure is taken, and only then is the resulting amount included in deductions. Paragraph 2 of article 264 defines related parties more broadly than the everyday notion of a group: they are the persons listed in article 14 of the code, legal entities belonging to the same group of companies as a parent that directly or indirectly holds their shares and participation interests, and individuals and legal entities where the other connecting factors set out in that article are present. The concept of a state with preferential taxation is set out in article 20 of the code, and the arm’s-length dimension of such transactions is covered in Transfer Pricing in Kazakhstan in 2026: the Local File, the Master File and Country-by-Country Reporting.

Fixed assets: four groups, maximum rates and the 300 MCI threshold

Fixed assets are property, plant and equipment, investment property, intangible and biological assets recognised on acquisition in the taxpayer’s accounting records and intended for use in activity directed at deriving income in the reporting or future periods.

Paragraph 1 of article 275 treats five categories as fixed assets: the assets listed above; assets with a service life of more than one year received by a concessionaire from a grantor under a concession agreement; assets with a service life of more than one year received by a trustee; subsequent expenditure on property received under a property lease (tenancy) agreement other than a finance lease, recognised as a long-term asset; and, in the hands of a lessor, property transferred under a property lease (tenancy) agreement and not carried after transfer as property, plant and equipment.

Paragraph 2 of article 275 excludes from fixed assets, among others, assets on which no depreciation is charged in accounting (with carve-outs for concession assets and assets carried at fair value); public-use structures — roads, pavements, boulevards and public gardens, other than concession facilities; property, plant and equipment whose cost has already been fully deducted; intangible assets with an indefinite useful life; and objects of investment tax preferences during the control period.

Deductions on fixed assets consist of three elements (article 274): depreciation charges under article 280, subsequent expenditure under article 281, and the value balance at the end of the tax period in the cases of paragraphs 2, 4 and 5 of article 282.

Depreciation charges are computed for each item of group I and for each of groups II, III and IV as a whole by applying the depreciation rates set by the taxpayer in the tax register to the value balance at the end of the tax period; those rates must not exceed the maximum rates set by paragraph 2 of article 280.

The maximum rate is a ceiling, not a mandatory figure. A company may set a lower rate in its tax register for fixed assets, and this is a legitimate tool for managing losses: understating depreciation in a loss-making year avoids burning a deduction that would then have to be carried forward as a loss.

Double depreciation rates in the first tax period of operation are available only to a narrow group of taxpayers. Paragraph 4 of article 280 allows depreciation at double rates in the first tax period of operation only to a subsoil user and only in respect of fixed assets put into operation in the Republic of Kazakhstan for the first time, on condition that those assets are used to derive aggregate annual income for at least three years. If such an asset is disposed of before the three-year period ends, the excess of the deduction taken over depreciation at the maximum rates is included in the aggregate annual income of the period in which the double rate was applied.

Subsequent expenditure on fixed assets is accounted for at the taxpayer’s choice. Paragraph 3 of article 281 gives the taxpayer the right to allocate subsequent expenditure, in the tax period in which it is incurred, either to deductions, or to an increase in the value balance of the relevant group, or to the creation of a value balance where no balance corresponding to that type of asset exists. The choice is made case by case and recorded in the tax accounts; it directly determines whether the company gets its deduction at once or spreads it over years through depreciation.

Small remaining value balances are written off in full. A taxpayer may deduct the value balance of an item of group I or the value balance of group II, III or IV at the end of the tax period where that balance is less than 300 times the monthly calculation index in force on the last day of the tax period (paragraph 4 of article 282). With the 2026 MCI of 4,325 tenge this threshold is 1,297,500 tenge.

Disposals are treated differently by group. On the disposal of an item of group I other than by a transfer free of charge, the value balance of that item at the end of the period is treated as the result of the disposal and accounted for under paragraphs 2 and 6 of article 340, while the balance itself is adjusted to zero and the adjustment is not deductible. On the disposal of all fixed assets of group II, III or IV, the value balance of that group at the end of the period is deductible. On a transfer free of charge of an item of group I or of all fixed assets of group II, III or IV, the value balance of that group is adjusted to zero and the adjustment is not deductible (paragraph 3 of article 282).

Investment tax preferences and the 100 per cent reduction of CIT

An investment tax preference is the right to deduct the costs included in the initial value of an object of preferences instead of depreciating that object under the general rules.

The class of eligible persons is defined negatively. Paragraph 1 of article 283 excludes participants of “Astana Hub”, participants of the Astana International Financial Centre, persons producing or selling all types of spirits, alcoholic products and tobacco products, and persons applying the special tax regime under section 16.

The objects of preferences are buildings, structures, machinery, equipment and software as classified in the state Classifier of Fixed Assets (paragraph 3 of article 283). Those assets must, throughout the control period, simultaneously satisfy six conditions: be recognised in accounting as property, plant and equipment, investment property or intangible assets, or be transferred by a lessor under a property lease (tenancy) agreement other than a finance lease, or be received by a concessionaire; be located in the Republic of Kazakhstan (the condition does not apply to intangible assets, machinery and equipment); be used in activity directed at deriving income; not form part of the costs of a subsoil use contract; not be used within an investment priority project under an investment contract or an investment agreement; and not be used within priority activities by participants of special economic zones.

The control period is a period of not less than three tax periods following the tax period in which the object of preferences is recognised (paragraph 6 of article 283).

There are two methods of applying the preferences, and the choice is recorded in the tax register for each object. The method of deduction after recognition of the object means deducting the initial value in the tax period in which the object is recognised. The method of deduction before recognition of the object means deducting the costs included in the initial value in the period in which those costs are actually incurred (paragraphs 2 and 3 of article 284). During the control period the objects of preferences are accounted for separately from fixed assets, object by object.

The cost of getting preferences wrong is high. The preferences are cancelled with effect from the date they were first applied, and the taxpayer must reduce deductions by the amount of the preferences for every tax period in which they were applied, if during the control period article 283 is breached, or the taxpayer comes to satisfy any of the conditions in paragraph 1 of article 283, or the taxpayer is reorganised by way of merger, accession, division or spin-off (paragraph 1 of article 285). An ordinary intra-group reorganisation carried out in the third year after an asset is put into service cancels the preference retrospectively.

The practical side of applying preferences and their interaction with investment contracts is covered in Investment Preferences and the Investment Contract in Kazakhstan in 2026: the New Architecture After the 1 January Reform.

Separately from investment preferences, the code retains regimes that reduce the tax itself rather than the base. An organisation carrying on activity in the territory of a special economic zone reduces the corporate income tax computed under article 345 by 100 per cent in respect of income from the sale of goods, work and services that are the result of carrying on priority activities (paragraph 4 of article 735). Income from other activities is taxed under the general rules (paragraph 7 of article 735), and paragraph 8 prohibits such an organisation from applying any other provision of the code that reduces CIT by 100 per cent. Participants of “Astana Hub” that satisfy the conditions of article 17 reduce the computed corporate income tax by 100 per cent (subparagraph 1) of paragraph 1 of article 738); chapter 82 and article 17 apply until 1 January 2029 by virtue of subparagraph 3) of paragraph 2 of article 848. The conditions for retaining participant status are covered in Astana Hub in 2026: New Participation Rules, the Auditor-Confirmed Report and the New Counter-Obligations.

Costs that are never deductible

Non-deductible costs are the expenses expressly listed in article 286 of the code, which do not reduce aggregate annual income regardless of documentary support or commercial justification.

The list in article 286 contains seventeen items. It covers costs not connected with activity directed at deriving income; expenses on transactions carried out without work actually being performed, services actually being rendered or goods actually being shipped; penalties, fines and late-payment interest payable to the budget, other than those payable under public procurement contracts; the excess of capped expenses over the maximum deductible amount; taxes and budget payments computed and paid above the amounts prescribed by law; the value of property transferred free of charge; contributions to reserve funds other than those permitted by articles 268, 301 and 323; and the carrying amount of assets transferred for temporary possession and use under a property lease (tenancy) agreement other than a finance lease.

Two items on that list deserve separate treatment because they change ordinary commercial practice.

Subparagraph 13) of article 286: expenses of an individual entrepreneur registered as a VAT payer, or of a legal entity, in favour of another individual entrepreneur registered as a VAT payer, or of a legal entity, under a civil-law transaction settled in cash inclusive of VAT, are not deductible in the amount exceeding 1,000 times the monthly calculation index in force on the date of payment, regardless of how frequently payment is made. With the 2026 MCI of 4,325 tenge the threshold is 4,325,000 tenge per transaction.

Subparagraph 16) of article 286: expenses on the acquisition of goods, work and services from persons applying the special tax regime based on a simplified declaration on the date those goods, work or services are received are not deductible. The date of receipt of goods is the date of their actual transfer to the buyer on the basis of supporting documents, and the date of receipt of work and services is the date the completion certificate or another document confirming performance is signed. This rule inverts the logic of supplier selection: buying from a supplier on the simplified regime increases the buyer’s tax base by the full amount of that purchase, and the counterparty’s tax regime must be checked as at the date of receipt rather than the date of the contract.

Article 272 of the Tax Code adds its own prohibition on taxes. The following are not deductible: taxes excluded before the determination of aggregate annual income; corporate income tax and taxes on income or profit of the same nature paid in Kazakhstan and in other states; taxes paid in states with preferential taxation; excess profits tax; and the alternative subsoil use tax (paragraph 2 of article 272).

A separate mechanism is the reversal of costs already deducted. Article 287 requires the exclusion of costs recognised in earlier tax periods where: the transactions were carried out without actual performance with a taxpayer whose director or founder was not involved in its registration or activity, as established by a court judgment in force; the transactions were with a taxpayer declared inactive, from the date of the decision declaring it inactive; the amounts appear in invoices whose issue has been found by a court judgment or by a decision of a criminal investigation body to have been made without actual performance; or the expenses relate to a transaction declared invalid by a court judgment in force. Disputes over additional assessments of this kind are handled by the UPPERSETUP legal team. The practical logic of desk control over such transactions is covered in Desk Control, Tax Audits and Appeals in Kazakhstan in 2026: Tax Code 214-VIII, the Administrative Procedure Code and Three Routes to a Dispute.

Reducing taxable income: four per cent, two hundred per cent and leasing

The reduction of taxable income is the mechanism under article 337 that reduces taxable income once it has been computed by reference to particular expenses and income; unlike a deduction, it is applied after the formula in article 236 has been worked through.

Charitable giving is capped differently for two categories of payer. Taxpayers that were under large-taxpayer monitoring during the tax period, other than participants of horizontal monitoring, reduce taxable income by charitable assistance and the value of property transferred free of charge to non-commercial organisations and social-sphere organisations in a total amount not exceeding 3 per cent of taxable income. All other taxpayers apply a limit of 4 per cent of taxable income. A mandatory condition for charitable assistance is a decision of the taxpayer taken on the basis of an application from the recipient.

Social and staff-related expenditure is taken into account at enhanced multiples. Subparagraph 3) of paragraph 1 of article 337 allows taxable income to be reduced by twice the expenses on the remuneration of persons with disabilities and by 50 per cent of the social tax computed on the wages and payments made to such persons. Social entrepreneurship entities included in the register reduce their income by the costs of training particular categories of employee, but by no more than 120 times the monthly calculation index in force on 1 January of the relevant financial year per employee per tax period, and only once for each employee.

Expenses on training an individual who is not an employee are allowed on condition that an agreement is signed obliging that individual to work for the taxpayer for at least three years. The code lists what such expenses comprise — tuition fees, accommodation and allowances within the limits set by the authorised body, travel to and from the place of study, and sickness insurance while abroad — and two situations in which the relief does not apply: failure to conclude an employment contract within three months of the completion of training, and termination of the employment contract before three years have elapsed, unless the individual reimburses the costs.

The largest relief is aimed at research. Subparagraph 6) of paragraph 1 of article 337 allows taxable income to be reduced by 200 per cent of the expenses deducted under article 269 on research, scientific-technical and development work connected with the creation of an object of industrial property and on the acquisition of exclusive rights to intellectual property from higher education institutions, scientific organisations, autonomous education organisations and start-up companies.The condition is that the work is carried out, or the results implemented, in the Republic of Kazakhstan; the supporting document is a certificate of implementation of the results of scientific and scientific-technical activity in the form determined by the authorised body for science. Together with the deduction under article 269 itself, the tax base is reduced by an amount equal to three times the actual expenditure.

Paragraph 2 of article 337 reduces taxable income by reference to income rather than expenses. Subparagraph 1) allows a reduction of 50 per cent of the interest under a finance lease agreement, excluding penalties, but by no more than 50 per cent of the taxable income for the reporting period determined before the article 337 reduction. The same paragraph covers interest on debt securities on the official list of the Kazakhstan stock exchange; interest on agency bonds; gains on the sale, by open trading on the exchange, of securities on the official list; and gains on the sale of shares and participation interests in a resident where the conditions of subparagraph 7) are met.

Loss carry-forward: ten years and the cases where the rule does not work

A loss from entrepreneurial activity is the negative result of the formula in paragraph 1 of article 236.

A loss from entrepreneurial activity for a tax period is carried forward successively to the following ten tax periods inclusive and is compensated out of the taxable income of those tax periods (paragraph 1 of article 339). The word “successively” means that losses are used in the order in which they arose, not selectively.

The second part of paragraph 1 of article 339 describes a separate mechanism for controlled foreign companies: the taxable income of CFCs and of permanent establishments of CFCs, other than those registered in states with preferential taxation, is reduced by losses from entrepreneurial activity in Kazakhstan arising in the reporting period and the two preceding periods. Losses already used against other objects of taxation are not counted again.

There is a direct exception to the general rule. Paragraph 2 of article 339: losses from entrepreneurial activity incurred by a bank’s subsidiary that acquires doubtful and bad assets of the parent bank are not carried forward to subsequent tax periods.

In parallel, the code treats the loss on disposal of long-term tangible assets as a separate category. Article 340 covers losses on the disposal of group I fixed assets, of construction in progress, of uninstalled machinery and equipment, and of assets with a service life of more than one year that are neither fixed assets nor inventories. Such a loss is not taken into account in the tax period for which it is determined and is carried forward successively to the following ten tax periods inclusive (paragraph 6 of article 340). Form 100.01 provides line 100.01.049 for it, with four sub-lines, one for each type of asset disposed of.

The code contains three further special categories of loss: the loss on disposal of investment assets (article 341), the loss on a derivative financial instrument (article 342) and the loss on an item of intellectual property in priority activities (article 343, which applies until 1 January 2029). Article 344 governs the transfer of losses on a reorganisation.

Advance payments: the 600,000 MCI threshold, form 101.02 and the 20 per cent fine

An advance payment of corporate income tax is a monthly payment to the budget on account of the tax for the current tax period, credited against the CIT computed in the return (paragraph 2 of article 347).

The first question is whether the company has to pay advances at all. Taxpayers are not liable to pay advance payments where their aggregate annual income, after adjustments, for the tax period preceding the previous tax period does not exceed an amount equal to 600,000 times the monthly calculation index of the year preceding the previous financial year (subparagraph 1) of paragraph 1 of article 348).

For the 2026 tax period both figures are taken for 2024. The MCI in force from 1 January 2024 under article 9 of Law of the Republic of Kazakhstan No. 43-VIII ZRK of 5 December 2023 “On the Republican Budget for 2024–2026” is 3,692 tenge, so the threshold for exemption from advance payments in 2026 is 600,000 × 3,692 = 2,215,200,000 tenge of aggregate annual income for 2024.

Besides the income threshold, paragraph 1 of article 348 exempts from advance payments newly incorporated taxpayers, during the period of state registration and the following period; newly registered non-residents with a permanent establishment and no structural subdivision, on the same terms; non-commercial organisations applying paragraph 1 of article 329 and article 330; organisations of persons with disabilities under article 331; participants of “Astana Hub” (until 1 January 2029); the organisation specialising in improving the quality of second-tier banks’ loan portfolios; the bodies and organisations of the Astana International Financial Centre; and subsoil users on onshore gas projects.

A strict exception has been carved out of those exemptions. Paragraph 2 of article 348: the exceptions provided for by subparagraphs 1)–9) of paragraph 1 do not apply to taxpayers carrying on activity in the field of digital assets. A digital asset company pays advances regardless of the size of its income and even in its first year of operation. The regulatory framework for that activity is covered in Digital Assets and Mining in Kazakhstan 2026: National Bank and AIFC Licences, Crypto Exchange and Taxation.

The calculation of advances is split into two blocks, and the first of them requires no action from the company. Advance payments for the first quarter of the reporting tax period are computed (assessed) by the tax authority for each month of the first quarter in an amount equal to one twelfth of the total advance payments computed in the calculations of advance payments for the previous tax period, including additional calculations (paragraph 2 of article 349). Order No. 695 approves no separate calculation form for advance payments for the first quarter. Only persons who were liable to pay advance payments in the previous tax period pay first-quarter advances (paragraph 1 of article 349), and payment is due by the 25th day of each month of the first quarter.

The second block is advances after the return. Advance payments for the second, third and fourth quarters are computed for each month in an amount equal to one twelfth of the CIT computed for the previous tax period under paragraph 1 of article 345 and article 689, excluding CIT on the aggregate profit of controlled foreign companies (subparagraph 1) of paragraph 2 of article 350). The calculation is made on the basis of the estimated CIT for the current period in three cases: where the CIT for the previous period is zero, including zero figures in reporting generated automatically by the tax authority’s information system; where a legal entity newly created by division or spin-off is liable to pay advance payments; and where the taxpayer carries on activity in the field of digital assets.

The calculation of advance payments after the return on form 101.02 is filed with the tax authority at the taxpayer’s registered address by 20 April of the reporting tax period (paragraph 3 of article 350). An additional calculation adjusting the advance payments on the basis of the estimated CIT for the current period may be filed by 31 December of the reporting tax period, and the adjusted amounts may not be negative (paragraph 4 of article 350). Advance payments after the return are due by the 25th day of each month of the second, third and fourth quarters (paragraph 5 of article 350).

Form 101.02 is extremely compact: line 101.02.001 is the CIT computed for the previous tax period; line 101.02.002 is the estimated CIT for the current tax period, including the estimate adjusted by deducting advances already declared; line 101.02.003 is the monthly advance payment, computed as 101.02.001/12 or 101.02.002/12.

Understating advances is penalised separately from understating the tax itself. Part 3 of article 278 of the Code of the Republic of Kazakhstan on Administrative Offences No. 235-V of 5 July 2014: where the corporate income tax actually computed for a tax period exceeds the advance payments computed during that tax period by more than twenty per cent, a fine of twenty per cent of the amount of that excess applies. Note 3 to article 278 closes the obvious workaround: liability also arises where the calculations of advance payments are not filed during the tax period, and in that case the computed advance payments are deemed to be zero, so the fine is measured against the full amount of tax.

Form 100.00 in its 2026 version: two lines in the return and fourteen appendices

The corporate income tax return (form 100.00) is the tax reporting form used to compute CIT, approved by appendix 2 to Order of the Minister of Finance of the Republic of Kazakhstan No. 695 of 12 November 2025.

Paragraph 1 of the explanation to the form defines who files it: form 100.00 is completed by resident legal entities and by non-resident legal entities acting through a permanent establishment, other than state institutions, subsoil users filing form 150.00, and subsoil users under the contracts referred to in paragraph 1 of article 755 of the code, who file form 110.00. For the non-contract activity of such a subsoil user it is form 100.00 that is completed.

Paragraph 2 of the explanation: the return consists of the return itself (form 100.00) and its appendices — forms 100.01 to 100.14. Paragraph 6 relieves the taxpayer of the obligation to complete appendices where there are no data to report; paragraph 7 requires a further identical appendix sheet where the number of indicators exceeds the lines available on the appendix sheet. Paragraph 10 permits the return to be drawn up in Kazakh and/or Russian and, on paper, in two copies. Paragraph 12 states expressly that this form applies to legal relations arising from 1 January 2026.

The main structural change in the 2026 version can be stated in a single sentence. The return 100.00 itself now contains only two computational lines: line 100.00.001, the total computed CIT, determined as the sum of lines 100.01.061 of all completed forms 100.01, and line 100.00.002, the total net income, determined as the sum of lines 100.01.062 of all completed forms 100.01 (paragraph 14 of the explanation). The entire computation has been moved into the appendix.

Appendix 100.01 is completed separately for each activity marker and separately for activity under a trust management agreement (paragraph 16 of the explanation). This is what makes article 345 workable: the separate computation at 20, 25, 5, 6 and 3 per cent is delivered not by columns in one table but by separate copies of form 100.01 inside a single return.

Form 100.01 follows the logic of section 5 of the code and is made up of five sections: “General information about the taxpayer”, “Aggregate annual income” (lines 100.01.001–100.01.021), “Deductions” (lines 100.01.022–100.01.044), “Computation of taxable income (loss)” (lines 100.01.045–100.01.053) and “Computation of the tax liability” (lines 100.01.054–100.01.063).

The key control ratios of form 100.01 reproduce the formulas of the code literally:

Line 100.01.021 — aggregate annual income after reduction and adjustments: the sum of lines 100.01.001–100.01.020, plus or minus the adjustment under article 256 (line 100.01.021 I), plus or minus the transfer pricing adjustment (100.01.021 II), less the reduction under article 255 (100.01.021 III), less income exempt under double tax treaties and under the Constitutional Law on the Astana International Financial Centre (100.01.021 IV).

Line 100.01.044 — total deductions after adjustment: line 100.01.043 plus or minus the adjustment of deductions under article 288 (100.01.044 I) plus or minus the transfer pricing adjustment (100.01.044 II).

Line 100.01.045 — taxable income: 100.01.021 – 100.01.044 where the result is positive; the same difference where negative is reported in line 100.01.046 as a loss.

Line 100.01.054 — taxable income after losses carried forward: 100.01.051 – 100.01.052; where the difference is negative, zero is entered. Line 100.01.055 — the CIT rate under article 357. Line 100.01.056 = 100.01.054 × 100.01.055.

Line 100.01.057 — the CIT computed under article 345: line 100.01.056 less the foreign tax credit (100.01.057 I, carried over from form 100.05), the CIT withheld on winnings and interest under paragraph 1 of article 351 (100.01.057 II), the CIT withheld under paragraph 2 of article 351 (100.01.057 III), the CIT withheld at source and carried forward from previous periods (100.01.057 IV), and the CIT under articles 690 and 691 (100.01.057 V); where the result is less than zero, zero is entered.

Line 100.01.061 — total computed CIT: 100.01.057 – 100.01.058 + 100.01.060. Line 100.01.062 — the net income of a non-resident acting through a permanent establishment: 100.01.054 – 100.01.056. Line 100.01.063 I — CIT on net income at 15 per cent.

The rules for issuing electronic invoices, which serve as the primary support for a large share of deductions, are covered in E-Invoices and the Virtual Warehouse in Kazakhstan in 2026: Order No. 629, Biometrics on Issuance and the New Deadlines, and the interaction between deductions and input VAT is covered in VAT in Kazakhstan 2026: Registration, the 10,000 MCI Threshold, the 16% Rate, e-Invoices and Refunds. Preparing form 100.00 with its appendices and reconciling the control ratios are covered by UPPERSETUP accounting support.

A step-by-step algorithm: twelve steps from closing the year to paying the tax

The CIT computation and payment algorithm is the sequence of actions a taxpayer takes from closing the accounting year to remitting the tax, tied to the deadlines in articles 347, 350 and 359 of the code.

1.       Close the accounting year under international financial reporting standards and prepare the profit and loss account, the balance sheet and the inventory schedules at the beginning and the end of the period — lines 100.01.022 I and 100.01.022 II are taken directly from the balance sheet.

2.       Identify the activity markers under paragraph 2 of article 357 and decide how many copies of form 100.01 you will complete: one where a single rate applies, several where concessionary activities or trust management are present.

3.       Assemble aggregate annual income in lines 100.01.001–100.01.020, separating out income from sales, gains, income from doubtful liabilities, income from the write-off of liabilities, and income from sources outside Kazakhstan (appendix 100.05).

4.       Apply the reduction of aggregate annual income under article 255, the adjustments under article 256 and the transfer pricing adjustments, and arrive at line 100.01.021.

5.       Build deductions in lines 100.01.022–100.01.042, starting with the cost of goods, work and services sold: line 100.01.022 is a nine-component formula in which the inventory movement is reduced by amounts non-deductible under article 286, by subsequent expenditure and by the initial value of fixed assets.

6.       Test the capped deductions: 1 per cent for representation expenses, the limiting-coefficient formula for interest, and 3 per cent for services and royalties from related parties in states with preferential taxation. Enter only the amounts within the caps in lines 100.01.027, 100.01.028 and 100.01.029: the excess is not deductible by virtue of subparagraph 4) of article 286.

7.       Compute deductions on fixed assets in appendix 100.02, applying depreciation rates no higher than the maximum rates, deciding how to treat subsequent expenditure (deduct now or increase the value balance) and testing the 300 MCI threshold on small remaining balances; carry the total to line 100.01.039.

8.       Arrive at taxable income (line 100.01.045) or a loss (line 100.01.046) and apply the reduction of taxable income under article 337 — charity within 3 or 4 per cent, 200 per cent for research and development, 50 per cent of finance lease interest.

9.       Use prior-year losses within the ten-year window (line 100.01.052) and determine taxable income after losses carried forward (line 100.01.054); where the difference is negative, enter zero and record the loss to be carried forward in line 100.01.053.

10.    Apply the rate under article 357 (line 100.01.055), compute the tax (line 100.01.056) and reduce it by the foreign tax credit under article 346 and by the CIT withheld at source — arriving at lines 100.01.057 and 100.01.061.

11.    File the return on form 100.00, together with all the necessary appendices, with the tax authority at the taxpayer’s registered address by 31 March of the year following the reporting tax period (paragraph 1 of article 359) and pay the tax within ten calendar days after the deadline for filing the return(paragraph 2 of article 347).

12.    If you are liable to pay advance payments, file the calculation on form 101.02 by 20 April and pay monthly advances by the 25th day of each month; where the forecast changes materially, file an additional calculation by 31 December so that the deviation of the actual tax from the advances stays within 20 per cent.

Deadlines, late-payment interest and administrative fines

The deadline for paying corporate income tax is ten calendar days after the deadline set for filing the CIT return (paragraph 2 of article 347).

The CIT tax period is the calendar year from 1 January to 31 December (paragraph 1 of article 358). For a legal entity created after the start of the calendar year, the first tax period runs from the date of creation to the end of the year, and the date of creation is the date of state registration with the registering authority. On liquidation or reorganisation, the final tax period runs from the start of the year to the date the liquidation or reorganisation is completed.

The CIT return is filed with the tax authority at the taxpayer’s registered address by 31 March of the year following the reporting tax period (paragraph 1 of article 359). A separate deadline applies to controlled foreign companies: where approved financial statements do not exist on the date the return is filed, the aggregate profit of CFCs is computed in an additional return filed within sixty working days of the approval of the financial statements, but no later than 31 March of the second year following the reporting period (paragraph 4 of article 359).

Tax withheld at source runs on its own calendar. A tax agent must remit the CIT withheld at source no later than twenty-five calendar days after the end of the month in which the income was paid (paragraph 1 of article 355) and file the calculation of the tax withheld no later than the 15th day of the second month following the quarter in which the payment was made (article 356).

Late payment attracts interest linked to the National Bank rate. Subparagraph 2) of article 5 of the code defines late-payment interest as amounts computed as a multiple of the base rate of the National Bank of the Republic of Kazakhstan in force on each day of delay, charged on the tax or budget payment, including advance and current payments, not paid on time, starting from the day following the due date and including the day of payment to the budget. The multiple of the base rate is 0.65 for a participant of horizontal monitoring and 1.25 for other taxpayers and tax agents.

The base rate of the National Bank of the Republic of Kazakhstan is 16.25 per cent per annum with a corridor of plus or minus one percentage point; the decision of the Monetary Policy Committee reducing the rate to that level was published on 4 September 2026 and is recorded under 7 September 2026 in the National Bank’s schedule of decisions. The next scheduled base rate decision is set for 23 October 2026, so where a delay spans the end of October the base rate must be checked for each day of delay separately.

With the 2026 MCI of 4,325 tenge, a repeated failure to file a return costs a large business entity 302,750 tenge, a medium-sized business entity 194,625 tenge and a small business entity 129,750 tenge.

Common mistakes

Mistake one: a single form 100.01 for all types of activity. Paragraph 16 of the explanation to the form requires appendix 100.01 to be completed separately for each activity marker, and paragraph 2 of article 345 requires the tax to be computed separately for each type of activity. A company that has mixed income at 20 per cent with income at a concessionary rate in one form produces an incorrect line 100.00.001 and runs the risk of an additional assessment under part 1 of article 278 of the Administrative Code.

Mistake two: buying from a supplier on the simplified declaration without checking its regime.Subparagraph 16) of article 286 disallows the deduction of expenses on goods, work and services acquired from persons applying the special tax regime based on a simplified declaration as at the date of receipt. The counterparty’s regime is tested at the date the goods are actually transferred or the completion certificate is signed, not at the date of the contract, so a change in the supplier’s regime mid-year removes the deduction on subsequent supplies.

Mistake three: representation expenses without the full set of documents. Paragraph 2 of article 262 requires an order to hold the event, an approved budget, a report by the responsible persons and primary documents, all at the same time. A restaurant bill on its own is not a basis for deduction, and the accommodation and air travel of invited persons are excluded from representation expenses outright by paragraph 4 of article 262 and are not deductible at all.

Mistake four: computing the article 264 limit by reference to revenue. The 3 per cent cap is measured against the taxable income of the reporting period determined before the deduction of the expenses covered by article 264 — not against aggregate annual income and not against the value of the services themselves. An error in the base of the cap usually overstates the deduction several times over.

Mistake five: ignoring the additional calculation of advance payments. A company whose profit has grown compared with the previous year keeps paying advances on the old figure and ends the year with an excess of more than 20 per cent. An additional calculation on form 101.02 may be filed up to 31 December of the reporting period, and that is the only lawful way to avoid the fine under part 3 of article 278 of the Administrative Code.

Mistake six: losing the CIT withheld at source. Paragraph 1 of article 345 allows the computed tax to be reduced by CIT withheld at source during the tax period only where documents confirming the withholding exist, and paragraph 4 of the same article allows the unused part to be carried forward within the limitation period. If lines 100.01.057 II–IV are left empty, there will be nothing to carry forward.

Mistake seven: reorganising during the control period for investment preferences. Subparagraph 3) of paragraph 1 of article 285 cancels preferences from the date they were first applied where the taxpayer is reorganised by merger, accession, division or spin-off, and the control period is at least three tax periods after the object is recognised. A corporate restructuring planned without regard to that provision forces a recomputation of deductions for all prior years.

Whom the general regime suits, whom it does not, and when a professional review is needed

The general CIT regime suits companies with a substantial share of documented expenses, because tax is paid on profit rather than turnover; capital-intensive businesses that use depreciation and investment tax preferences; exporters and groups with foreign income that need the foreign tax credit under article 346; companies with cyclical profits for which the ten-year loss carry-forward is critical; and residents conducting research and development, because taxable income may be reduced by 200 per cent of that expenditure.

The general CIT regime does not suit micro businesses with a minimal share of documented expenses, for which a special tax regime is usually cheaper; companies whose main suppliers apply the simplified declaration, because subparagraph 16) of article 286 removes the deduction on such purchases; structures relying on deducting services and royalties from related parties in low-tax jurisdictions, since the 3 per cent cap in article 264 devalues that model; and companies without tax registers, because paragraph 4 of article 257 makes a deduction depend directly on documentary support.

A professional review is necessary in five situations: where several activity markers with different rates, and therefore several forms 100.01, are involved; where there are transactions with related parties and non-residents, in which article 264, the transfer pricing rules and article 682 operate together; where investment tax preferences with a control period are applied; where controlled foreign companies and the foreign tax credit under article 346 are present; and in the first year after the transition from the former Tax Code, when the accounting policy and tax registers still carry references to repealed provisions. Such a review is carried out by the UPPERSETUP accounting team together with the legal team.

Frequently asked questions

What corporate income tax rate applies in Kazakhstan in 2026?

The standard rate is 20 per cent of taxable income (subparagraph 5) of paragraph 2 of article 357). For the banking activity of second-tier banks, other than income from lending to business entities, and for casinos, slot-machine halls, totalisators and bookmakers the rate is 25 per cent. Social-sphere organisations pay 5 per cent for the period from 1 January to 31 December 2026 and 10 per cent from 1 January 2027. Producers of agricultural and aquaculture products pay 3 per cent, and agricultural cooperatives pay 6 per cent.

When must form 100.00 be filed and the tax for 2026 be paid?

The corporate income tax return for 2026 is filed by 31 March 2027 with the tax authority at the taxpayer’s registered address (paragraph 1 of article 359). Payment is due within ten calendar days after the deadline set for filing the return (paragraph 2 of article 347), that is by 10 April 2027.

For how many years can a loss be carried forward?

A loss from entrepreneurial activity is carried forward successively to the following ten tax periods inclusive and is compensated out of the taxable income of those periods (paragraph 1 of article 339). The same ten-year term is set by paragraph 6 of article 340 for a loss on the disposal of long-term tangible assets. The exception is the losses of a bank’s subsidiary that acquires doubtful and bad assets of the parent bank: those are not carried forward at all.

Who is exempt from CIT advance payments in 2026?

Exempt are taxpayers whose aggregate annual income after adjustments for 2024 did not exceed 600,000 times the 2024 MCI, that is 2,215,200,000 tenge, as well as newly incorporated taxpayers during the period of registration and the following period, non-commercial organisations under paragraph 1 of article 329 and article 330, organisations of persons with disabilities, participants of “Astana Hub” and a number of other persons (paragraph 1 of article 348). No exception applies to taxpayers carrying on activity in the field of digital assets (paragraph 2 of article 348).

What depreciation rates apply to fixed assets?

Paragraph 2 of article 280 sets the maximum rates: 10 per cent for group I (buildings and structures other than oil and gas wells and transmission devices), 25 per cent for group II (machinery and equipment other than oil and gas production equipment, and computers and information-processing equipment), 40 per cent for group III (computers, software and information-processing equipment) and 15 per cent for group IV (other assets, including wells and transmission devices). A taxpayer may set a lower rate in its tax register.

Can expenses on services from a related company in a low-tax jurisdiction be deducted?

Yes, but only within a cap. Article 264 limits the deduction of management, consultancy, consulting, audit, design, legal, accounting, advocate’s, advertising, marketing, franchising, financial, engineering and agency services, royalties and rights to use intellectual property acquired from a related party registered in a state with preferential taxation to a total of no more than 3 per cent of the taxable income of the reporting period determined before the deduction of those expenses.

What happens if advance payments turn out to be materially lower than the actual tax?

Part 3 of article 278 of the Code on Administrative Offences imposes a fine of twenty per cent of the excess where the corporate income tax actually computed for the tax period exceeds the computed advance payments by more than twenty per cent. Under note 3 to that article, liability also arises where calculations of advance payments are not filed, and in that case the computed advances are deemed to be zero. The sanction is avoided by filing an additional calculation on form 101.02 no later than 31 December of the reporting period.

Must all fourteen appendices to form 100.00 be completed?

No. Paragraph 5 of the explanation to the form provides that appendices are completed where lines of the return requiring the disclosure of the relevant indicators are filled in, and paragraph 6 states expressly that appendices are not completed where there are no data to report in them. In practice every payer completes appendix 100.01, because lines 100.00.001 and 100.00.002 are built exclusively from its totals.

Key takeaways

Corporate income tax in Kazakhstan in 2026 is computed under Code of the Republic of Kazakhstan No. 214-VIII ZRK of 18 July 2025, in force from 1 January 2026; the only amendment to the code is Law of the Republic of Kazakhstan No. 308-VIII of 11 June 2026, effective 1 July 2026 and terminological in nature.

The standard rate is 20 per cent; 25 per cent applies to the banking activity of second-tier banks other than income from lending to business entities, and to the gambling business; 5 per cent in 2026 and 10 per cent from 2027 apply to social-sphere organisations; and 3 and 6 per cent apply to agriculture.

Taxable income is determined by the formula TI/L = AGI – R +(–) IA – D +(–) DA (paragraph 1 of article 236), and the base to which the rate is applied is arrived at after the reduction under article 337 and the loss carry-forward under articles 339–344 (paragraph 2 of article 345).

Three caps determine the quality of deductions: 1 per cent of the employer’s expenses on employee income for representation expenses, a limiting coefficient of 4 or 7 in the interest deduction formula, and 3 per cent of taxable income for services and royalties from related parties in states with preferential taxation.

Depreciation is capped at 10, 25, 40 and 15 per cent across four groups, a value balance below 300 MCI is written off in full, and subsequent expenditure on fixed assets goes, at the taxpayer’s choice, either straight to deductions or to an increase in the value balance.

A loss is carried forward for ten tax periods inclusive; exemption from advance payments in 2026 applies where aggregate annual income for 2024 did not exceed 2,215,200,000 tenge; the calculation on form 101.02 is filed by 20 April and the adjustment by 31 December.

The return on form 100.00 is filed by 31 March and the tax is paid within ten calendar days after that deadline, and the form as approved by order No. 695 contains only two computational lines — the entire computation has moved into appendix 100.01, completed separately for each type of activity.

What you need to know about corporate income tax in Kazakhstan in 2026

Corporate income tax in Kazakhstan in 2026 is governed by the Tax Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025, which entered into force on 1 January 2026 and replaced the 2017 code. The standard CIT rate is 20 per cent of taxable income. An increased rate of 25 per cent applies to second-tier banks on banking activity other than income from lending to business entities, and to casinos, slot-machine halls, totalisators and bookmakers. Social-sphere organisations pay 5 per cent in 2026 and 10 per cent from 1 January 2027. Producers of agricultural products pay 3 per cent and agricultural cooperatives pay 6 per cent. Income taxed at source is taxed at 15 per cent, the net income of a non-resident’s permanent establishment at 15 per cent, and the taxable income of controlled foreign companies at 20 per cent. Taxable income is computed as aggregate annual income less the reduction under article 255, plus or minus the income adjustment under article 256, less deductions, plus or minus the deduction adjustment under article 288. Losses are carried forward for ten years. Depreciation is charged across four groups with maximum rates of 10, 25, 40 and 15 per cent. Representation expenses are capped at 1 per cent of the employer’s expenses on employee income, services and royalties from related parties in states with preferential taxation at 3 per cent of taxable income, and charity at 3 per cent for large taxpayers under monitoring and 4 per cent for everyone else. The return is filed on form 100.00 by 31 March of the following year, the tax is paid within ten calendar days after that deadline, advance payments are due by the 25th day of each month, and the calculation on form 101.02 is filed by 20 April. Exemption from advance payments applies where aggregate annual income for 2024 did not exceed 600,000 MCI, that is 2,215,200,000 tenge. Late-payment interest is computed from the National Bank base rate at a multiple of 1.25; the base rate has been 16.25 per cent per annum since 4 September 2026.

If you need help computing CIT, preparing form 100.00 or setting up tax accounting in Kazakhstan, contact the UPPERSETUP specialists: we support companies from company registration through to annual reporting, and an overview of the jurisdiction is available at Business Setup in Kazakhstan: Company Registration and Accounting Services.

Sources

Level 1 — legislation and regulator materials

1.       Code of the Republic of Kazakhstan No. 214-VIII ZRK of 18 July 2025 “Tax Code of the Republic of Kazakhstan” — Adilet legal information system.

2.       Article 5 of Code No. 214-VIII, “Concepts relating to tax debt” (definition of late-payment interest and the multiple of the base rate) — Adilet.

3.       Section 5 “Corporate income tax”, chapters 23–38 of Code No. 214-VIII (articles 233–359) — Adilet.

4.       Article 848 of Code No. 214-VIII, “Procedure for bringing this Code into force” — Adilet.

5.       Section 17 of Code No. 214-VIII, “Tax preferences and reliefs based on contracts (agreements)”, articles 734–745 — Adilet.

6.       Article 682 of Code No. 214-VIII, “Rates of income tax withheld at source” — Adilet.

7.       Amendment footnote in Code No. 214-VIII: Law of the Republic of Kazakhstan No. 308-VIII of 11 June 2026, in force from 1 July 2026 (consolidated text of the Code) — Adilet.

8.       Order of the Minister of Finance of the Republic of Kazakhstan No. 695 of 12 November 2025 “On the approval of tax reporting forms with explanations for their completion and the Rules for their submission” (registered with the Ministry of Justice on 12 November 2025, No. 37390) — Adilet.

9.       Appendix 2 to order No. 695 — form 100.00 “Corporate income tax return” and the explanation for its completion — Adilet.

10.    Appendix 3 to order No. 695 — form 101.02 “Calculation of advance payments of corporate income tax payable for the period after filing the return” — Adilet.

11.    Law of the Republic of Kazakhstan No. 239-VIII ZRK of 8 December 2025 “On the Republican Budget for 2026–2028” (article 7: MCI of 4,325 tenge from 1 January 2026) — Adilet.

12.    Law of the Republic of Kazakhstan No. 43-VIII ZRK of 5 December 2023 “On the Republican Budget for 2024–2026” (article 9: MCI of 3,692 tenge from 1 January 2024) — Adilet.

13.    Code of the Republic of Kazakhstan No. 235-V of 5 July 2014 “On Administrative Offences”, articles 272 and 278 — Adilet.

14.    Press release of the National Bank of the Republic of Kazakhstan “On the reduction of the base rate to 16.25% following the forecasting round” of 4 September 2026 — National Bank of the Republic of Kazakhstan.

15.    Schedule of base rate decisions of the National Bank of the Republic of Kazakhstan — National Bank of the Republic of Kazakhstan.

Disclaimer

This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before making any decision, obtain individual professional advice that takes into account your specific situation, jurisdiction, company status and the current requirements of the regulators. Current as at September 2026.