Dividends and Profit Repatriation from a Kazakh LLP in 2026: What Happened to the Three-Year Holding Relief

Kazakhstan no longer grants any dividend relief based on how long a participation has been held. The rule that exempted dividends where the shares or participation interest had been held for more than three years applied until 31 December 2022, survived for three more years in reduced form as a 10% rate, and disappeared altogether on 1 January 2026 with the repeal of the old Tax Code. The statute now looks at the size of the holding rather than its duration: a participant holding at least 25% of the capital of a Kazakh LLP pays 5% on dividends up to 230,000 times the monthly calculation index per calendar year and 15% above that ceiling. Every other non-resident pays 15%, and a recipient registered in a listed preferential-tax jurisdiction pays 20% regardless of holding size or duration.

Alert. Check the date the dividend was accrued before you compute the tax. Code No. 214-VIII contains no transitional rule addressed to dividends — the word does not appear anywhere in the final and transitional block, articles 837 to 848. One qualification: articles 837 and 838 preserve the conditions provided by investment contracts and investment agreements concluded before 1 January 2026, so a holder of such a contract should check those provisions separately. In a reply of 2 March 2026 to individual enquiry No. ЖТ-2026-00553796 the State Revenue Committee took the position that the law in force at the date of accrual governs, so that a dividend accrued for 2025 and paid in 2026 falls under the former Code. Author’s assessment: that reply was given through the eOtinish enquiry system, is not published on kgd.gov.kz, addresses individual income tax only, and says nothing about corporate withholding on a non-resident participant. It has no normative force. The money at stake is real: under the former Code a non-resident holding for more than three years paid 10%, while under the current Code the rate is 5% or 15% depending on the size of the holding and the amount.

The legal stack: which instruments govern an LLP dividend in 2026

Paying a dividend out of a Kazakh LLP engages four separate layers of law — the Tax Code, the LLP statute, the currency legislation and the tax treaties. They were enacted by different bodies and change at different speeds, so they should not be run together.

The tax layer:

•          Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025 — the Tax Code now in force. Brought into effect on 1 January 2026 by its own article 848, which simultaneously repealed Code No. 120-VI of 25 December 2017. Two carve-outs from that date: article 189 applies from 1 July 2026, and article 92 together with Chapter 90 from 1 January 2027. Article 848(2) also sets five groups of provisions with limited lives — expiring on 1 January 2027, 2028, 2029, 2030 and 2031 — and certain provisions of Code No. 120-VI survive to 1 January 2027 and 1 January 2029. The provisions that matter here are articles 13 (the meaning of dividends), 20(preferential-tax states), 255 (reduction of aggregate annual income), 263 (interest deduction), 264 (deductions on dealings with a related non-resident), 332 to 336 (controlled foreign companies), 351 and 357 (income taxed at source and corporate rates), 363 (individual rates), 400 and 436 (reduction of an individual’s income), 679 and 681 to 685 (non-resident income, exemptions, rates, withholding and reporting) and 698 to 706 (application of tax treaties).

•          Law No. 308-VIII of 11 June 2026 — the only amendment to the Code as at 1 July 2026, which is the date to which the available text is consolidated. Checked as at August 2026: no amendment to the Code after 1 July 2026 could be found — one mirror records that the text was re-verified on 30 July 2026, and none of the articles examined in this article carries a later amendment note. In force from 1 July 2026 and terminological in nature; it does not touch the dividend provisions.

•          Law No. 239-VIII of 8 December 2025 on the Republican Budget for 2026-2028, article 7: the monthly calculation index for 2026 is KZT 4,325, effective 1 January 2026. Articles 363 and 682 of the Code direct that the index in force on 1 January of the relevant financial year be used, so the figure does not move during the year.

•          Order of the Minister of Finance No. 492 of 12 September 2025 approving the list of preferential-tax states, registered with the Ministry of Justice on 16 September 2025 under No. 36853 and in force from 1 January 2026. Its Appendix 2 repealed Order No. 142 of 8 February 2018 together with the amending Orders No. 920 of 25 September 2020 and No. 1215 of 30 November 2022.

•          Order of the Minister of Finance No. 579 of 6 October 2025 — the list of 40 states whose nominal profit tax rate exceeds 75% of the Kazakh corporate rate, for the purposes of article 332. Registered on 7 October 2025 under No. 37079, in force from 1 January 2026, replacing Orders No. 680 of 19 June 2023 and No. 247 of 22 May 2025.

Repealed provisions that can no longer be relied on:

•          Article 645(9)(4) and (5) of Code No. 120-VI — the exemption for a non-resident’s dividends on a holding of more than three years. Deleted by Law No. 135-VII of 11 July 2022 with effect from 1 January 2023.

•          Article 646(4) and (5) of Code No. 120-VI — the 10% rate on a holding of more than three years, which ran from 1 January 2023 to 31 December 2025. It has no successor in Code No. 214-VIII.

•          Article 341(1)(8) of Code No. 120-VI — the adjustment of a resident individual’s income capped at 30,000 times the monthly calculation index a year. Not carried into Code No. 214-VIII.

•          Article 241(2)(2) of Code No. 120-VI — the bar on removing from aggregate annual income dividends paid by a company that had reduced its corporate tax by 100%. Not carried into Code No. 214-VIII.

The corporate layer: Law No. 220-I of 22 April 1998 on Limited and Additional Liability Partnerships, in force as amended to August 2026. Articles 11 (participants’ rights), 40 (distribution of net income), 43 (competence of the general meeting) and 48 (how decisions are taken).

The currency layer: Law No. 167-VI of 2 July 2018 on Currency Regulation and Currency Control, as amended by Law No. 259-VIII of 16 January 2026. National Bank Management Board Resolutions No. 40 of 30 March 2019 (rules on carrying out currency operations), No. 64 of 10 April 2019 (monitoring) and No. 42 of 30 March 2019 (export-import control), as amended by Resolution No. 29 of 31 March 2026, which also amended Resolution No. 294 of 29 November 2018.

The treaty layer: the double tax conventions — the State Revenue Committee’s published list carries 55 entries but is dated 29 November 2023 and does not reflect later treaties, notably the convention with Oman which entered into force on 10 June 2026, applied as modified by the Multilateral Instrument, ratified by Law No. 304-VI of 20 February 2020 and in force for Kazakhstan from 1 October 2020.

Author’s assessment: the official legal portal adilet.zan.kz is closed to automated access. Every statutory text in this article is therefore taken from mirrors that reproduce the official editions verbatim — pavlodar.com, kodeksy-kz.com, zakon.uchet.kz and prg.kz — together with the State Revenue Committee and National Bank websites. The source of each quotation is identified in the list of sources.

What counts as a dividend: two species, including constructive dividends

Code No. 214-VIII splits dividends into two species — dividends arising from a distribution of income, and constructive dividends — and defines them in a dedicated article 13. The split is new: the former Code No. 120-VI carried a single flat definition in article 1.

A dividend from a distribution of income is defined in article 13(2) across six limbs. Four matter for an LLP:

•          net income, or part of it, distributed by a legal entity among its founders and participants — the ordinary dividend;

•          income from a distribution of property on liquidation or on a reduction of charter capital, and on a buy-back by the entity of a participant’s participation interest or part of it — so a participant’s exit and a liquidation are taxed as dividends rather than as capital gains;

•          an increase in the contribution to charter capital funded out of the entity’s own equity — capitalising retained earnings is treated as paying a dividend even though no money moves. Excluded from this limb are additional paid-in capital representing the excess of the value of property received by an issuer on placing its shares over the nominal value of those shares, additional contributions by a participant to the entity’s property, and revaluation surpluses. For an LLP only the second and third carve-outs can bite, since a partnership has neither shares nor a nominal value;

•          income on unit investment fund units and Islamic participation certificates — not relevant to an LLP.

Income from a distribution of property is computed under the formula in article 13(4): D = Sp − Su, where Sp is the book value of the property received at the date of transfer, disregarding revaluation and impairment, and Su is the paid-up charter capital attributable to the participation interest, taking account of the participant’s additional contributions to the entity’s property and of any increase in charter capital funded from equity, but capped at the original cost of that participation interest.

A constructive dividend is defined in article 13(3) in two limbs:

“1) received by a shareholder, participant, founder or a related party from a legal entity, arising on an adjustment of objects of taxation and (or) objects connected with taxation, made in the cases and in the manner established by the transfer pricing legislation of the Republic of Kazakhstan”.

“2) received by a shareholder, participant, founder or their related party from a legal entity in the form of: the value of costs or obligations unconnected with the entrepreneurial activity of the legal entity, arising for its shareholder, participant, founder or their related party towards a third person and discharged by the legal entity without reimbursement…; any property and material benefit provided by the legal entity to its shareholder, participant, founder or their related party, other than employee income and income from the sale of goods, works and services”.

Royalties for the use of patented industrial property are expressly excluded from the second limb.

The practical significance of constructive dividends is that a transfer pricing adjustment automatically becomes a dividend. If the Kazakh authorities adjust the price of a transaction between the LLP and its foreign participant, the adjustment is charged not only to corporate tax in the LLP’s hands but also to withholding tax as a dividend of the participant. That doubling is on its own a reason to have transfer pricing documentation ready in advance.

Author’s assessment: interest disallowed under the thin capitalisation rule does not become a dividend. Article 263 caps the interest deduction by a formula in which the maximum debt-to-equity coefficient is 4 for ordinary legal entities, including microfinance organisations, and 7 for financial organisations. The excess is simply not deductible; article 263 contains no recharacterisation language. The recharacterisation risk arrives from a different direction — through article 13(3), because a non-arm’s-length rate on a participant loan can be adjusted under the transfer pricing rules and, as a consequence of that adjustment, treated as a constructive dividend.

The corporate step: how an LLP resolves to distribute

An LLP distributes net income by resolution of an ordinary general meeting of participants for a quarter, half-year or year, and payment must be made in money within one month of the resolution. The source is article 40 of Law No. 220-I:

“1. Distribution among the participants of a limited liability partnership of net income received by the partnership from its activity for a quarter, half-year or year may be made in accordance with a resolution of the ordinary general meeting of participants of the partnership devoted to approving the results of the partnership’s activity for the quarter, half-year or year. The general meeting is also entitled to resolve to exclude net income or part of it from distribution among the participants of the partnership.

2.        Where the general meeting of a limited liability partnership resolves to distribute income among the participants, each participant is entitled to receive the part of the distributed income corresponding to its share in the charter capital of the partnership. Payment must be made by the partnership in monetary form within one month of the date on which the general meeting resolved to distribute the net income.

3.        A limited liability partnership is not entitled to distribute income among participants until the whole of the partnership’s charter capital has been paid up.”

Interim distributions are expressly permitted: the statute names the quarter and the half-year alongside the year. There is no separate interim dividend regime and no additional restriction on interim distributions.

The resolution passes by simple majority. Approving the financial statements and distributing net income fall within the exclusive competence of the general meeting under article 43(2)(4). Article 48(2) requires a qualified three-quarters majority only for the matters in subparagraphs 1), 7), 9) and 10) of article 43(2) — amending the charter, reorganisation and liquidation, compulsory buy-out of a participation interest, and pledging the whole of the property. Distribution is not among them, so it is decided by a simple majority of the participants present and represented, unless the charter sets a higher threshold.

The only restriction on distribution is unpaid charter capital. That is a material departure from what many investors expect.

Author’s assessment: Law No. 220-I contains neither a net assets test nor a solvency test for the distribution of net income. The net assets requirement in article 27 governs payments on a reduction of charter capital, not distributions of profit. That conclusion is drawn from the text of articles 26, 27 and 40 of Law No. 220-I; an exhaustive review of the Civil Code, the rehabilitation and bankruptcy legislation and the Supreme Court’s normative resolution on partnerships was not carried out, so the finding is stated as an absence in Law No. 220-I itself. The practical point is unaffected: distributing profit on negative net assets is not expressly prohibited by the LLP statute, but it remains vulnerable in a later insolvency.

A participant cannot compel a distribution. Article 11(1)(3) gives a participant the right to receive income “in accordance with this Law, the constituent documents of the partnership and the resolutions of its general meeting”, and article 40(1) expressly permits the meeting to exclude net income from distribution. Combined with the simple-majority threshold, that means a majority participant can withhold distribution indefinitely. Once a distribution is resolved, the participant’s right becomes a money claim payable within one month.

Author’s assessment: Law No. 220-I does not provide for distribution otherwise than in proportion to charter capital. Article 40(2) ties each participant’s share of the distributed income to its share in charter capital and carries no “unless the charter provides otherwise” qualification. The practice of jurisdictions where the charter can vary the proportion should not be read across.

The mechanics of forming and running the partnership itself are set out in LLP (TOO) in Kazakhstan for Foreigners.

Where the three-year holding relief went: a repeal in two stages

The holding-period relief was repealed twice — first for non-residents and resident individuals with effect from 1 January 2023, and then finally with effect from 1 January 2026. The chronology matters commercially, because a great deal of published material still describes rules that ceased to apply three years ago.

Stage zero — the position before 2023. Article 645(9)(4) of Code No. 120-VI exempted a non-resident’s dividends where three conditions were met at once:

“on the day the dividends are accrued the taxpayer has held the shares or participation interests on which the dividends are paid for more than three years; the resident legal entity paying the dividends is not a subsoil user during the period for which the dividends are paid; the property of persons who are subsoil users represents no more than 50 per cent of the value of the assets of the resident legal entity paying the dividends on the day the dividends are paid.”

The exemption expressly did not apply to persons registered in a preferential-tax state. A mirror provision for resident individuals sat in article 341(1)(8) and imposed the same three conditions.

Stage one — 1 January 2023. Law No. 135-VII of 11 July 2022 deleted subparagraphs 4) and 5) of article 645(9).The consolidated text of the former Code carries the footnote “excluded in accordance with the Law of 11.07.22 No. 135-VII” at that point. The State Revenue Committee accompanied the change with a notice, “Taxation of dividends: what changes take effect next year?”, published on 11 November 2022.

The full exemption was replaced by a 10% rate in new paragraphs 4 and 5 of article 646, which kept the three-year holding test and carried two further conditions across into the new provision:

•          the 100% corporate tax reduction condition. If the payer reduced its assessed corporate tax by 100% and the share of that reduced tax in total assessed corporate tax was 50 per cent or more, the reduced rate did not apply at all; if the share was under 50 per cent, the reduced rate applied to the whole dividend. Author’s assessment: this condition was not a 2023 invention — in the edition of Code No. 120-VI in force from 1 January 2019 it sat in a note appended to article 645, and Law No. 135-VII moved it into the body of article 646;

•          a previously-taxed condition. The provision applied “only to income previously charged to corporate income tax”.

At the same time article 646 allowed the holding period to be aggregated with that of previous owners on a reorganisation, and on an acquisition of the interest from another legal entity where both entities had the same founders.

For resident individuals the three-year test was replaced from the same date by an income adjustment capped at 30,000 index units per calendar year and a single 10% rate.

Stage two — 1 January 2026. Code No. 214-VIII reproduced none of it: not the 10% rate, not the three-year test, not the 100% corporate tax reduction condition, and not the 30,000-unit adjustment.

The check was made against exhaustive lists:

•          Article 681, “Income of a non-resident not subject to taxation in the Republic of Kazakhstan”, has 15 subparagraphs. The only dividend limb is subparagraph 7), which exempts dividends on securities on the official list of a Kazakh stock exchange that were traded on the exchange during the calendar year “in accordance with the criteria determined by the Government of the Republic of Kazakhstan”. A participation interest in an LLP is not a security, so subparagraph 7) is structurally unavailable to an LLP.

•          Article 682, “Rates of income tax at the source of payment”, has three paragraphs and contains no holding-period condition of any kind.

•          Article 400, on reductions of an individual’s taxable income, has 24 subparagraphs, none of which covers dividends. Article 436, to which subparagraph 24) refers, has 13 subparagraphs and ends with dividends on exchange-listed securities. No 30,000-unit cap survives anywhere in the Code.

•          Article 255, on reductions of aggregate annual income for resident companies, has two paragraphs and contains no 100% corporate tax reduction condition.

Author’s assessment: the repeal of the 100% corporate tax reduction condition is a separate liberalisation that is easy to miss. Before 2026, dividends paid by a company that had enjoyed a corporate tax exemption could fall outside the relief altogether. No such restriction now applies to residents or non-residents. The finding rests on the absence of the rule from articles 255, 681 and 682 and on the absence of the phrase “reduction of assessed corporate income tax by 100 per cent” from the new Code’s texts; not all 848 articles were read individually.

Where a three-year holding test still operates

The three-year test survives in two places in the Code, and neither concerns dividends.

The first is a non-resident’s capital gain on debt securities. Article 681(9) exempts such gains on conditions that recognisably echo the old dividend rule:

“income from a gain in value on the disposal of debt securities issued by a resident legal entity, other than income of a person that is a resident of a preferential-tax state, where the following conditions are met simultaneously: on the day of disposal of the debt securities the taxpayer has held those debt securities for more than three years; that issuing legal entity is not a subsoil user; the property of persons who are subsoil users represents no more than 50 per cent of the value of the assets of that issuing legal entity on the day of such disposal.”

The subsoil qualification has been refined: a person is not treated as a subsoil user where its only such right is to extract groundwater or commonly occurring minerals for its own needs.

The second is a resident individual’s capital gain on a participation interest. Article 400(1)(4) preserves the reduction of income where shares or participation interests in a resident legal entity have been held for more than three years, on the same subsoil conditions and the same 50 per cent asset test.

The practical point: in Kazakhstan a three-year holding now relates to exiting an investment, not to receiving income from it. A sale of the interest may qualify for relief; a distribution of profit does not.

What is being taxed	Does a three-year holding test apply in 2026	Basis
Dividends from an LLP to a non-resident	No	Articles 681 and 682 contain no holding-period condition
Dividends from an LLP to a resident individual	No	Articles 400 and 436 do not list dividends
Dividends from an LLP to a resident company	No, and none is needed — the reduction is unconditional	Article 255(1)(1)
A non-resident’s gain on the disposal of debt securities	Yes, more than three years	Article 681(9)
A resident individual’s gain on the disposal of a participation interest	Yes, more than three years	Article 400(1)(4)
Dividends on exchange-listed securities	No test; relief rests on a different basis	Articles 681(7) and 436(13)

What a non-resident pays in 2026

Dividends paid by a Kazakh LLP to a non-resident are taxed at source at 15%, or on a 5% and 15% progressive scale where the recipient holds at least 25% of the capital, or at 20% where the recipient is registered in a preferential-tax jurisdiction.

Dividends are Kazakhstan-source income of a non-resident under article 679(1)(12): “income in the form of dividends received from a resident legal entity, and also from unit investment funds established in accordance with the laws of the Republic of Kazakhstan”.

The rates sit in article 682:

“5) income from a gain in value, dividends, interest, royalties, other than the income specified in subparagraphs 6) to 7) of this paragraph — 15 per cent;

6)       dividends paid to a person directly or indirectly holding not less than twenty-five per cent of the capital of the resident legal entity paying the dividends: up to 230,000 times the monthly calculation index (inclusive) — 5 per cent; above 230,000 times the monthly calculation index — the amount of tax on taxable income of 230,000 times the monthly calculation index plus 15 per cent on the excess”.

“2. Income of a person registered in a preferential-tax state is taxed at the source of payment at a rate of 20 per cent.”

“3. Income from a gain in value on the disposal of shares… of participation interests… and also dividends received from the legal entities specified in article 17 of this Code, are taxed at the source of payment at a rate of 5 per cent.”

Paragraph 3 concerns participants in Astana Hub as defined by article 17. None of the three paragraphs applies to a non-resident operating in Kazakhstan through a permanent establishment.

The LLP itself withholds, as tax agent, under article 683. Article 683(6) allows an agent to pay the tax from its own funds without withholding — but that choice carries a consequence dealt with below: article 698(3) then denies any treaty benefit.

The tax must be remitted within twenty-five calendar days after the end of the month in which payment was made(article 684(1)(1)), translated at the official rate on the date of payment. For income accrued but unpaid and taken as a deduction a different deadline applies — within ten calendar days after the corporate tax return date.

Reporting is on form 101.04, the calculation of corporate income tax withheld at source from a non-resident’s income. Article 685 sets the deadlines: for the first, second and third quarters, by the 15th day of the second month following the quarter; for the fourth quarter, by 31 March of the year following the reporting tax period.

The withholding mechanics across all categories of non-resident income, including services and royalties, are set out in Withholding Tax in Kazakhstan.

The 25% threshold and the 230,000-unit ceiling in practice

The reduced 5% rate applies where the recipient holds, directly or indirectly, at least 25% of the capital of the paying LLP, and it runs up to 230,000 times the monthly calculation index — KZT 994,750,000 for 2026.

The arithmetic: 230,000 × 4,325 = KZT 994,750,000. The index is taken as at 1 January of the relevant financial year and is not revised during the year.

Four points where the calculation commonly goes wrong.

First, the threshold is measured by capital rather than votes, and indirect holdings count. The wording “directly or indirectly holding not less than twenty-five per cent of the capital” is wider than direct participation: a chain of companies producing 25% or more in aggregate satisfies it. There is no holding-period requirement at all — an interest acquired the day before payment satisfies the threshold exactly as one held for ten years.

Second, the scale applies to income for the calendar year cumulatively rather than to each payment separately — but for non-residents that is the authority’s position, not the text of the statute. The Code is asymmetric here. For resident individuals article 363(3) says so expressly: “dividend income taxed for the calendar year”. Article 682, which governs non-residents, contains no equivalent — the words “for the calendar year”, “in aggregate” and “cumulatively” appear nowhere in it, and the single footnote to the scale addresses only the date on which the index is fixed. The annual period for non-residents comes from the State Revenue Committee’s clarification of 3 November 2025 on enquiry No. ЖТ-2025-03599536, which ties the scale to income for the calendar year by reference to articles 679, 682 and 692.

Author’s assessment: that clarification is available only in secondary reproductions rather than on kgd.gov.kz, was given on an individual enquiry, and has no normative force. A check of articles 682, 683, 692 and 221 found no textual basis for annual aggregation. The practical consequence is nonetheless direct: a tax agent is safer computing cumulatively, because the opposite approach produces an understatement that will surface on audit.

Third, the excess is not taxed wholly at 15% but under a “tax on 230,000 units plus 15% on the excess” formula.The lower slice remains at 5% even once the ceiling is passed.

Fourth, the 25% threshold and the 20% rate do not combine. Where the recipient is registered in a preferential-tax jurisdiction, article 682(2) imposes 20% irrespective of the size of the holding, and the reduced scale does not operate.

Worked through at 2026 values, for a holding of at least 25% and a recipient outside the listed jurisdictions:

Dividends for the calendar year	Computation	Tax	Effective rate
KZT 500,000,000	500,000,000 × 5%	KZT 25,000,000	5.00%
KZT 994,750,000 (exactly 230,000 units)	994,750,000 × 5%	KZT 49,737,500	5.00%
KZT 1,500,000,000	49,737,500 + (505,250,000 × 15%)	KZT 125,525,000	8.37%
KZT 3,000,000,000	49,737,500 + (2,005,250,000 × 15%)	KZT 350,525,000	11.68%

Author’s computation on the rates in article 682(1)(6) and an index of KZT 4,325. For comparison, a holding below 25% would attract 15% on the whole of each figure, and a recipient in a listed jurisdiction 20% on the whole.

Preferential-tax jurisdictions: the 2026 list and the 20% rate

Article 20 treats a foreign state or territory as a preferential-tax state where its profit tax rate is below 10 per cent, or where it has laws on the confidentiality of financial information or permitting the beneficial owner to be concealed. The two limbs are alternatives, not cumulative conditions.

The second limb does not apply to a state with which Kazakhstan has a treaty providing for exchange of tax information — except where that state does not in fact provide the exchange. Article 20(2) defines that failure by two markers: a written refusal by the foreign competent authority to supply information covered by the treaty, or a failure to supply requested information for more than two years after a request. Note that a treaty on exchange of information does not save a jurisdiction from the first limb, the sub-10 per cent rate.

The operative list was approved by Order of the Minister of Finance No. 492 of 12 September 2025 and contains 56 positions. The Order came into force on 1 January 2026 and replaced Order No. 142 of 8 February 2018 together with the amending Orders No. 920 of 25 September 2020 and No. 1215 of 30 November 2022.

Author’s assessment: in substance the 2026 list reproduces the previous one as it stood on 1 December 2022. Order No. 492 is a re-enactment under the new article 20 rather than a revision of the content; no addition or deletion relative to the final edition of Order No. 142 could be identified.

Ten of the 56 positions are not states at all but particular territories of states. This drafting feature is regularly overlooked:

Position on the list	What is actually caught
Kingdom of Spain	The Canary Islands only
People’s Republic of China	The special administrative regions of Macau and Hong Kong only
Malaysia	The Labuan enclave only
Portuguese Republic	The Madeira islands only
Kingdom of Morocco	The city of Tangier only
Kingdom of the Netherlands	Aruba and the dependent Antilles territories only
New Zealand	The Cook Islands and Niue only
United Kingdom	Anguilla, Bermuda, the British Virgin Islands, Gibraltar, the Cayman Islands, Montserrat, the Turks and Caicos Islands, the Isle of Man, the Channel Islands, South Georgia, the South Sandwich Islands and the Chagos Archipelago
United States of America	The Virgin Islands, Guam, Puerto Rico and the State of Wyoming
French Republic	The Kerguelen Islands, French Polynesia and French Guiana

Delaware was removed from the list by Order No. 1215 with effect from 1 December 2022; Wyoming remains. That is the only instance of a US state appearing on the list.

What is absent from the list often matters more than what is on it. The list does not include the United Arab Emirates — not as a state, not as an individual emirate, and not as any free zone — nor Singapore, Cyprus or Liechtenstein. It does include Hong Kong (through the China position), Malta as a whole state, Montenegro, Colombia, Costa Rica, Lebanon, Morocco in respect of Tangier, Nigeria, the Philippines, Sri Lanka and Jamaica — several of which sit outside the conventional picture of an offshore jurisdiction.

Author’s assessment: the Ministry of Finance list should not be confused with the offshore-zones list maintained by the Agency for Regulation and Development of the Financial Market. These are two separate instruments with different content and different effects: the second applies to banks, insurers, professional securities market participants and microfinance organisations and has no bearing on taxation.

What else follows from the list: deductions and controlled foreign companies

Being on the list carries four consequences beyond the 20% rate.

First, a wider definition of Kazakhstan-source income. Article 679(1)(4) treats as Kazakh-source “income of a person registered in a preferential-tax state from the performance of works and the rendering of services irrespective of the place where they are actually performed or rendered”. Services performed entirely outside Kazakhstan are taxed at source at 20%.

Second, a cap on deductions. Article 264 limits the deduction of management, consultancy, audit, design, legal, accounting, advocacy, advertising, marketing, franchising, financial (other than interest expense), engineering and agency services, and of royalties and rights to use intellectual property, acquired from a related party registered in a preferential-tax state, to an aggregate not exceeding 3 per cent of taxable income for the reporting period computed before those deductions. The cap bites only for related parties.

Third, loss of the surviving exemptions. Subparagraphs 9), 11) and 13) of article 681 expressly exclude persons registered in, or resident in, a preferential-tax state from the exemptions for gains on debt securities and for Astana Hub-related income.

Fourth, automatic entry into the controlled foreign company perimeter. Article 332 treats a company as controlled where three conditions are met at once: it is not registered in a state on the Order No. 579 list; 25 per cent or more of its participation interests or voting shares belong directly, indirectly or constructively to a Kazakh resident as at 31 December; and its effective profit tax rate is below 10 per cent, or it is registered in a preferential-tax state. Registration on the list satisfies the third condition automatically, with no effective-rate computation required.

The exemptions are in article 334 and include an effective rate of taxation of 20 per cent or more and a share of passive income below 20 per cent. Article 332 itself further provides that a company is not treated as controlled where it has a financial loss or where its aggregate income is below 195 times the monthly calculation index. The rate on the taxable income of controlled foreign companies is 20 per cent (article 357(1)(5)), and the participation statement is due by 31 March of the year following the reporting period (article 336).

Author’s assessment: the commercially sharpest interaction is the absence of the UAE and Cyprus from the Order No. 579 list. That list of 40 states takes a company outside the first condition in article 332. Kazakhstan has double tax treaties in force with both the UAE and Cyprus, but neither appears among the 40 — so a UAE or Cyprus company fails the first condition and must be tested on the effective-rate limb instead. The regime is examined in Controlled Foreign Company Rules in Kazakhstan.

Dividends to a resident company: why the tax is nil

Dividends received by a Kazakh legal entity from another Kazakh legal entity are not withheld on and are fully removed from the recipient’s aggregate annual income, so the effective burden is nil.

The mechanism runs in two steps. The dividend first enters the recipient’s aggregate annual income. Article 255(1)(1) then takes it back out:

“For the purpose of determining taxable income, a taxpayer’s aggregate annual income is reduced by the following income: 1) dividends, other than those received by a permanent establishment of a non-resident legal entity in the Republic of Kazakhstan that do not meet the conditions set out in subparagraph 7) of article 681 of this Code”.

The sole carve-out concerns a non-resident’s permanent establishment. Where the dividend is received by a Kazakh permanent establishment of a foreign legal entity and does not satisfy article 681(7) — that is, does not relate to exchange-listed and actually-traded securities — the reduction does not apply. For an ordinary Kazakh LLP receiving dividends from a subsidiary LLP there are no conditions at all.

No withholding arises on a resident-to-resident payment. Article 351(1) lists the income of a resident legal entity that is taxed at source when paid by a resident: winnings and interest. Dividends are not on that list.

Author’s assessment: the position was different before 2026, and older commentary must not be carried across.Article 241(2)(2) of Code No. 120-VI barred the removal from aggregate annual income of dividends paid by a legal entity that had reduced its assessed corporate tax by 100%, where the share of that reduction was 50 per cent or more of total assessed corporate tax. A dividend caught by that bar was withheld on. Code No. 214-VIII contains no such bar.

The LLP’s own corporate rate depends on what it does, not on how it is owned. Article 357(2) sets 20% as the general rate; 25% for banking, casinos, gaming machine halls, totalisators and bookmakers; 3% for the production and processing of agricultural and aquaculture produce; 6% for agricultural cooperatives; and 5% in 2026, rising to 10% from 2027, for organisations operating in the social sphere.

The practical consequence is that a Kazakh holding tier above an operating LLP is tax-neutral. Profit moves up into the holding company without tax and without withholding; tax arises only when it leaves the Kazakh perimeter.

Dividends to a resident individual: why the 30,000-unit exemption disappeared

A resident individual’s dividends from a Kazakh LLP are charged to individual income tax on a progressive scale — 5 per cent up to 230,000 times the monthly calculation index for the calendar year and 15 per cent above it — with no exempt slice at all.

The rates are in article 363(3), where dividend income is taxed for the calendar year on a scale identical to the non-resident scale in article 682(1)(6). The index is applied as at 1 January of the relevant financial year — KZT 4,325, giving a ceiling of KZT 994,750,000 for 2026.

The income adjustment capped at 30,000 index units, which ran from 1 January 2023 to 31 December 2025, was not carried into the new Code. Both articles that could have contained it were checked: article 400 lists 24 categories of income eligible for reduction and dividends are not among them; article 436, to which article 400(1)(24) refers, contains 13 subparagraphs and ends at subparagraph 13) — dividends on securities on the official list of a Kazakh stock exchange that were traded during the calendar year. There is no subparagraph 14) and no mention of 30,000 index units anywhere in article 436.

The practical result is that a participant’s dividend from an ordinary LLP is taxed from the first tenge. The former rule exempted the first 30,000 index units — on the 2025 index, an amount of the order of KZT 118 million a year. From 2026 that amount is taxed at 5%.

Author’s assessment: the widely repeated “10% on an individual’s dividends” is out of date. The single 10% rate was introduced by Law No. 135-VII with effect from 1 January 2023 and applied until 31 December 2025. From 1 January 2026 the 5% and 15% scale applies. Sources quoting 10% are describing a repealed rule.

The three-year holding test applied to resident individuals until 31 December 2022 under article 341(1)(8) of Code No. 120-VI, on the same three conditions as the non-resident rule. No holding-period condition now attaches to an individual’s dividends; the three-year test survives only for gains on the disposal of a participation interest under article 400(1)(4).

The LLP withholds as tax agent. Dividends are income taxed at source under article 425(6). Article 440(3): “Individual income tax is withheld by the tax agent no later than the day of payment.” Remittance follows within twenty-five calendar days after the end of the month under article 440(4).

Tax treaties: when a convention helps and when it does not

A treaty is applied to dividends under article 706, not article 705, and since 2026 it almost never improves the position of a participant holding at least 25%.

This is the counter-intuitive heart of the subject. The domestic 5% rate for a holder of 25% or more, within the 230,000-unit band, is at or below the treaty rate in most relevant conventions, and under four treaties the domestic rate is plainly better.

State of residence of the recipient	Treaty rate on dividends	Ownership condition	Against the domestic 5% at a holding of 25%+
United Arab Emirates	5%	Direct holding of at least 10% of capital	Equal
Singapore	5% / 10%	Direct holding of at least 25% of capital	Equal at 25%+, worse below
Cyprus	5% / 15%	Direct holding of at least 10% of capital	Equal
Netherlands	5% / 15%, and 0% where section VII of the protocol is satisfied	At least 10% of capital directly or indirectly; for the nil rate, at least 50%	Equal, and better on the nil rate
United Kingdom	5% / 15%	Direct or indirect control of at least 10% of the voting shares	Equal
Türkiye	10%	No ownership condition	Worse than the domestic rate
Russia	10%	No ownership condition	Worse than the domestic rate
Uzbekistan	10%	No ownership condition	Worse than the domestic rate
Georgia	15%	No ownership condition	Worse than the domestic rate

Rates taken from the texts of the conventions as set out in the ratifying laws. Author’s assessment: a treaty cannot worsen a taxpayer’s position — it sets a ceiling, not a mandatory rate. The “worse than domestic” entries therefore mean not that more tax is due, but that invoking the treaty is pointless: at a holding of 25% or more and an amount within the ceiling, it is better to apply article 682(1)(6) and not assemble treaty documentation at all.

The nil rate under the Netherlands treaty deserves separate attention. Section VII(1) of the protocol exempts dividends from tax in the source state where the recipient holds, directly or indirectly, at least 50 per cent of the capitalof the payer and has made an investment in it of not less than USD 1,000,000 that is wholly guaranteed or insured by the government of the other state, its central bank or a government-controlled body, and approved by the government of the first state. Where the cover is partial, the exemption applies pro rata to the guaranteed portion. Author’s assessment: the termination clause in section VII(3) attaches not to this exemption but to the additional tax on permanent establishment profits under article 10(8); the section VII(1) exemption itself carries no sunset. The government-guarantee condition makes the provision hard to reach in practice, but it remains formally in force.

How the Kazakh and Emirati perimeters sit together in one structure is examined in Kazakhstan + UAE: The Dual Structure.

A treaty becomes valuable in three situations: where the holding is below 25% (domestic 15% against a possible treaty 5% or 10%); where amounts substantially exceed 230,000 index units; and where the recipient sits in a jurisdiction whose treaty rate is below 15%.

For a recipient in a listed jurisdiction a treaty is unhelpful for a different reason. Of the 56 positions, the great majority are either states with no Kazakh treaty in force (Malta, Montenegro, and Portugal, where a convention exists only in draft and has not entered into force) or territories carved out of their parent state’s treaty. The distinction is visible in Order No. 579, where the list of states with a nominal rate above 75% enters China with the qualification “the People’s Republic of China (other than in respect of the territories of the special administrative regions of Macau and Hong Kong)”. Author’s assessment: the relationship between article 682(2) and an applicable treaty is not resolved by the Code — the saving clause permitting treaty rates sits at the end of article 682(1), while paragraph 2 is drafted as a free-standing provision and is not expressed to operate notwithstanding a treaty. Article 22(5) of the Code meanwhile gives ratified treaties priority over the Code, and article 698 contains no carve-out for preferential-tax jurisdictions. No State Revenue Committee guidance and no court practice on this particular clash could be located, and the question remains open.

Author’s assessment: in practice the dispute can arise on only a handful of entries, where the territory is simultaneously covered by a convention in force. The sharpest case is the State of Wyoming: it is a full US state, and a Wyoming corporation that is a US tax resident falls squarely within the scope of the convention with the United States, in force since 30 December 1996. A similar if more contestable position arises for the Canary Islands (the Spain convention), the Labuan enclave (the Malaysia convention) and French Guiana, which sits inside French tax territory. For Hong Kong, Macau, Aruba, the British overseas territories and French Polynesia the question does not arise: they fall outside the territorial scope of the relevant conventions.

The three conditions in article 698 always apply. A treaty does not apply to a resident who uses its provisions in the interests of another person who is not resident in a contracting state. A treaty applies as modified by the Multilateral Instrument. And — a rule regularly overlooked — where the agent pays the tax from its own funds without withholding, the treaty does not apply at all (article 698(3)).

The Multilateral Instrument sits on top, but not uniformly across treaties. Kazakhstan ratified it by Law No. 304-VI of 20 February 2020; it entered into force for Kazakhstan on 1 October 2020, and Kazakhstan applies the principal purpose test together with the simplified limitation-on-benefits provision. Article 8 of the Instrument imposes a 365-dayholding requirement for a reduced dividend rate, and Kazakhstan entered no reservation excluding it.

Article 8 nevertheless operates only where both sides adopted it, and of the five relevant treaties that is true of one.Kazakhstan notified 54 covered tax agreements; Cyprus is not among them, so the Instrument does not touch the Cyprus treaty at all. The United Kingdom and Singapore each reserved under article 8(3)(a), disapplying article 8 entirely to their agreements. The UAE position paper could not be retrieved directly, but none of the four accessible synthesised texts of UAE treaties with counterparties that do apply article 8 carries the condition.

Treaty	Covered by the Instrument	Counterparty position on article 8	Does the 365-day condition apply
Netherlands	Yes	Adopted	Yes
United Kingdom	Yes	Reserved under article 8(3)(a)	No
Singapore	Yes	Reserved under article 8(3)(a)	No
UAE	Yes	Reserved (author’s assessment, on indirect evidence)	No
Cyprus	Not covered	Not applicable	No

Author’s assessment: the proposition that “Kazakhstan entered no reservation, so the 365-day rule applies” is wrong for four of the five treaties. The State Revenue Committee publishes the synthesised texts in .docx format, which is not amenable to automated checking; no Cyprus synthesised text appears among them, which is consistent with the Cyprus treaty not being a covered agreement.

The residency certificate and recovering over-withheld tax

To apply a treaty rate to dividends at the moment of payment, the tax agent must hold a document confirming the recipient’s residence no later than 31 March of the year following the tax period in which the payment was made.

The conditions for an agent to apply a treaty on its own initiative are in article 706(1): a treaty with the recipient’s state of residence has been concluded and ratified; the residence document has been provided within the period set by article 705(3) and meets the requirements of article 702; the income paid is not connected with the non-resident’s permanent establishment in Kazakhstan; and the non-resident is the final recipient of the income.

“For the purposes of this section, the final recipient of income means a person (the beneficial owner) who has the right to own, use and dispose of the income and is not an intermediary in relation to such income, including an agent or nominee holder.”

The certificate deadline is the earlier of two dates: 31 March of the year following the corporate tax period in which the income was paid, or no later than five working days before the completion of a tax audit on the discharge of the income tax obligation.

A copy goes to the tax authority. Article 706(3) requires the agent to file a copy of the document confirming the final recipient’s residence within five calendar days of the date set for filing the fourth-quarter return.

The requirements for the certificate itself are in article 702, which admits three forms: the original certified by the foreign competent authority, with signatures and seals legalised; a notarially certified copy of that original; or a paper copy of an electronic document from the foreign competent authority’s website. For the first two forms the statute also admits an electronic apostille as an alternative to legalisation.

Legalisation is not required where the document is posted on the foreign competent authority’s website, or where a different procedure is established by a treaty to which Kazakhstan is a party (the route through which the Hague Apostille Convention operates), by a mutual agreement under article 232, or by a decision of a Eurasian Economic Union body.

The period the certificate covers is fixed by article 702(3): where the document states a period, residence is recognised for that period; where it confirms residence as at a specific date, from 1 January of that year to that date; and where no period is stated at all, for the whole calendar year of issue or posting.

If the certificate does not arrive in time, no treaty rate is applied at payment. Article 706(4) obliges the agent to withhold and remit in the manner and within the deadlines of articles 683 and 684. The Code contains no express “late means lost” rule, and two recovery routes remain.

Route one — a refund through the tax agent, article 706(5). The final recipient is entitled to a refund of over-withheld tax, and the refund is made by the tax agent itself. The documents are submitted by the non-resident before the expiry of the limitation period running from the date the tax was last remitted to the budget. Having made the refund, the agent may file an additional form 101.04.

Route two — a refund from the budget, articles 699 to 701. The non-resident applies to the tax authority before the limitation period expires. For dividends the schedule of attachments is set separately by article 699(4) rather than by the general list in article 699(3), and comprises a statement from the central depositary account, the general meeting’s resolution on the payment of dividends, statements from foreign accounts and the residence document. The tax authority reviews the application within twenty working days and the refund is executed within thirty working days of the decision. The application is refused where a foreign competent authority fails to respond to a request for more than two years. An appeal is lodged within 90 calendar days and reviewed by the authorised body within 30 working days.

The limitation period is set by article 65 at five years for large taxpayers, subsoil users and certain listed categories and three years for other taxpayers, extended until a decision on a non-resident’s refund application has been executed.

Author’s assessment: the conditional bank deposit mechanism does not exist in Code No. 214-VIII. The former Code allowed withheld tax to be placed on a conditional bank deposit pending confirmation of treaty entitlement. A review of the sequence of articles 698 to 710 of the new Code shows no such provision, and a full-text search of the Code for the phrase returns nothing. A payment can no longer be planned around that instrument.

The currency perimeter: how the money actually leaves

The repatriation requirement does not apply to an outbound dividend — it applies only to exports and imports.This has to be settled first, because the two regimes are constantly conflated.

The heading of the provision decides the point: article 9 of Law No. 167-VI is titled “Requirement to repatriate national and (or) foreign currency on export or import” and obliges a resident to credit to accounts with authorised banks the proceeds of exports, and currency transferred to a non-resident under an import where the non-resident fails to perform. A dividend is an outbound payment and falls outside that structure. The remaining paragraphs of article 9 do not change this: paragraph 3 lists the circumstances in which the requirement is treated as discharged, paragraph 4 transfers the obligation on an assignment of the claim, and paragraphs 5 and 6 deal with monitoring and with delegation to the rules. Every one of them is anchored to the phrase “currency contracts on export or import”.

The permissive rule is in article 6(4) of the same law:

“Non-residents are entitled freely to receive and transfer dividends, interest and other income received on deposits, securities, loan and other currency operations with residents, in accordance with the currency legislation of the Republic of Kazakhstan.”

The 20 per cent penalty under article 251 of the Code of Administrative Offences is equally inapplicable to dividends, since that article is itself confined to exports and imports. The exposure on a dividend payment lies elsewhere: article 252 penalises carrying out currency operations in breach of the currency legislation, with a repeat offence within a year attracting between 20 and 100 per cent of the amount of the operation depending on the category of the offender.

No separate accounting number is assigned to a dividend payment. The reasoning runs as follows:

•          A “currency contract” under article 1 of Law No. 167-VI includes constituent documents. For a dividend, the currency contract is the LLP’s charter together with the resolution of the general meeting.

•          Capital movement operations include participation in capital. So where a foreign participant’s contribution to charter capital exceeded USD 500,000, an accounting number will already have been assigned to the constituent documents under the currency monitoring rules.

•          The dividend payment itself is not enumerated as a capital movement operation and needs no accounting number of its own. In reporting it carries currency operation code 1314, “dividends (distribution of profit)”.

The thresholds worth committing to memory:

Threshold	What it governs	Basis
USD 500,000	Assignment of an accounting number to a capital movement currency contract, including a contribution to charter capital	Currency monitoring rules, National Bank Resolution No. 64 of 10 April 2019
USD 50,000	Assignment of an accounting number to an export or import currency contract	Export-import currency control rules, Resolution No. 42 of 30 March 2019
USD 50,000 for legal entities, USD 10,000 for individuals	Threshold for providing details of a currency operation to the bank	Rules on carrying out currency operations, Resolution No. 40 of 30 March 2019
USD 10,000	Below this the currency contract need not be produced to the bank	Resolution No. 40

What the rules require the bank to be given. Paragraph 12 of Resolution No. 40 requires the currency contract or a copy to be produced — bearing the accounting-number mark where the contract is subject to one. Paragraph 16 requires details of the currency operation on the prescribed form, stating the currency contract particulars and the accounting number where one exists. Article 15 of Law No. 167-VI adds the country of registration of sender and beneficiary, an intra-group transfer flag and the currency operation code.

Author’s assessment: nothing in the currency rules requires proof of tax withheld to be shown to the bank.Paragraph 12 of Resolution No. 40 lists no tax document at all. The common assertion that a bank will not release a dividend without evidence that tax has been paid does not follow from the currency legislation; where such a demand is made it reflects the bank’s internal procedures or compliance policy rather than a statutory duty.

The bank may nonetheless demand justification. Article 21 of Law No. 167-VI permits an authorised bank to execute payments on operations that “may be directed at the withdrawal of money from the Republic of Kazakhstan”, and on operations “having no obvious economic sense”, only where the client provides consent to disclose information about the payment to the currency control and law enforcement authorities.

Changes in 2026. Law No. 259-VIII of 16 January 2026 amended articles 9 and 15 of Law No. 167-VI — the footnotes to both articles in the consolidated text cite it expressly. National Bank Resolution No. 29 of 31 March 2026 amended three instruments: Resolutions No. 294 of 29 November 2018, No. 40 and No. 64; its visible content is revised reporting forms 1-INV to 5-INV and 16-PB together with a suspension of digital verification requirements until 12 July 2026. Neither the 2026 Law nor the 2026 Resolution touched the substance of the repatriation requirement. The regime is examined in Currency Control in Kazakhstan.

Astana Hub and the AIFC: two reliefs that are constantly confused

Astana Hub delivers a 5 per cent rate at source; the Astana International Financial Centre delivers a full exemption until 1 January 2066. They are different regimes created by different instruments.

Astana Hub. Article 17 imposes three cumulative conditions: the entity is registered as a participant with the Astana Hub autonomous cluster fund; at least 90 per cent of its aggregate annual income comes from priority activities in information and communication technologies; and, where it produces and sells goods, those goods meet the own-production criteria. In computing the 90 per cent test the numerator additionally takes in, where connected with the priority activity, income from gratuitously received property, interest on deposits, the excess of positive over negative exchange differences, and income on doubtful obligations together with penalties and fines on them. Article 682(3) taxes dividends received from such entities at 5 per cent at source.

The AIFC. This relief sits not in the Tax Code but in article 6 of Constitutional Law No. 438-V of 7 December 2015 on the Astana International Financial Centre, paragraph 7 of which exempts individuals and legal entities until 1 January 2066 from individual and corporate income tax on income including:

“4) in the form of dividends on shares of participant legal entities registered in accordance with the acting law of the Centre, or on participation interests in the charter capital of participant legal entities registered in accordance with the acting law of the Centre”.

The relief is addressed to the investor, not merely to the Centre participant, and is not limited by residence: any individual or legal entity receiving dividends on a participation interest in an AIFC-registered company qualifies.

Author’s assessment: the new Tax Code did not repeal this relief and could not have done so. Article 6(1) of the Constitutional Law defines the Centre’s tax regime by reference to the Tax Code “save for the exemptions established by this article”, and the accompanying Law No. 215-VIII of 18 July 2025 is an ordinary law, which cannot amend a constitutional law. No 2025 or 2026 amendment to the Constitutional Law appears in the amendment records; that check was made against mirrors consolidated to 2024 and against the text published by the AIFC Court.

Substance requirements and a comparison of the regimes are set out in AIFC or LLP: Choosing a Jurisdiction Inside Kazakhstan.

Every rate, deadline and threshold for 2026 in one table

The table consolidates the parameters in force as at August 2026. The monthly calculation index is KZT 4,325 and 230,000 index units are KZT 994,750,000.

Parameter	Value	Basis
Dividend to a non-resident, general rate	15%	Article 682(1)(5)
Dividend to a non-resident holding at least 25% of capital	5% up to 230,000 units; then tax on 230,000 units + 15% on the excess	Article 682(1)(6)
Dividend to a recipient in a preferential-tax jurisdiction	20% regardless of holding	Article 682(2)
Dividend from an Astana Hub participant	5%	Articles 17 and 682(3)
Dividend on a participation interest in an AIFC company	Exempt until 1 January 2066	Constitutional Law No. 438-V, article 6(7)(4)
Dividend to a resident legal entity	0%: no withholding, removed from aggregate annual income	Articles 351(1) and 255(1)(1)
Dividend to a resident individual	5% up to 230,000 units; then tax on 230,000 units + 15%	Article 363(3)
Holding-period condition for dividends	None	Articles 681, 682, 400, 436
Three-year holding for a non-resident’s gain on debt securities	Applies, with a carve-out for preferential-tax jurisdictions	Article 681(9)
Three-year holding for a resident individual’s gain on a participation interest	Applies	Article 400(1)(4)
Withholding of individual income tax	No later than the day of payment	Article 440(3)
Remittance of corporate tax withheld at source	25 calendar days after the end of the month of payment	Article 684(1)(1)
Remittance of individual income tax withheld	25 calendar days after the end of the month	Article 440(4)
Non-resident reporting, quarters I to III	Form 101.04, by the 15th of the second month after the quarter	Article 685
Non-resident reporting, quarter IV	Form 101.04, by 31 March of the following year	Article 685
Residency certificate for treaty relief	By 31 March of the year following the period of payment, or 5 working days before completion of an audit	Articles 705(3) and 706(1)
Copy of the certificate to the tax authority	5 calendar days from the date set for fourth-quarter reporting	Article 706(3)
Refund of over-withheld tax through the agent	Before expiry of the limitation period	Article 706(5)
Refund from the budget: review / payment	20 working days / 30 working days	Article 700
Limitation period	3 years; 5 years for large taxpayers and subsoil users	Article 65
Payment after a distribution resolution	1 month, in money only	Law No. 220-I, article 40(2)
Majority required for a distribution resolution	Simple majority of those present and represented	Law No. 220-I, articles 43(2)(4) and 48(2)
Bar on distribution	Until charter capital is fully paid up	Law No. 220-I, article 40(3)
Accounting number for a capital movement currency contract	Above USD 500,000	National Bank Resolution No. 64
Threshold for providing operation details to the bank, legal entities	USD 50,000	National Bank Resolution No. 40
Currency operation code for a dividend	1314	Appendix to National Bank Resolution No. 40
Controlled foreign company (CFC) participation threshold	25% directly, indirectly or constructively, as at 31 December	Article 332
CFC effective rate threshold	below 10%, or registration in a preferential-tax state	Article 332
Tax rate on CFC profit	20%	Article 357(1)(5)
CFC participation statement	By 31 March of the following year	Article 336
Cap on deducting services from a related party in a listed jurisdiction	3% of taxable income	Article 264
Thin capitalisation coefficient	4 for ordinary entities, 7 for financial organisations	Article 263(5)(3)

Step by step: paying a dividend to a foreign participant

Step 1. Confirm that charter capital is fully paid up. Until it is, distribution is prohibited by article 40(3) of Law No. 220-I. This is the only unconditional bar.

Step 2. Prepare financial statements for the period. What is distributed is net income for a quarter, half-year or year, and the meeting is convened precisely to approve the results for that period.

Step 3. Hold an ordinary general meeting and minute it. A simple majority suffices unless the charter says otherwise. Record the period, the amount of net income being distributed and the allocation by participation interest.

Step 4. Establish the recipient’s status on three questions at once. Resident or non-resident. Company or individual. Registered in a state on the Order No. 492 list or not. Those three answers give the rate without further analysis.

Step 5. For a non-resident, check the size of the holding. At least 25 per cent directly or indirectly means the 5% and 15% scale. Below 25 per cent means 15%. Do not check the holding period: it no longer matters.

Step 6. Compute cumulatively for the calendar year. The 230,000-unit ceiling applies to dividends for the year, not to an individual payment. On second and later payments, take earlier ones into account.

Step 7. Decide whether a treaty is worth invoking. At a holding of at least 25 per cent and an amount within the ceiling, the domestic 5% is usually no worse than the treaty rate and the documentation does not repay itself. Below 25 per cent, or above the ceiling, compare against the treaty rate.

Step 8. If you are applying a treaty, obtain the residency certificate early. It must comply with article 702 and reach the agent no later than 31 March of the year following the period of payment. Check whether it is posted on the foreign competent authority’s website, in which case legalisation is unnecessary.

Step 9. Satisfy yourself that the recipient is the final recipient of the income. Article 706(1)(4) requires that it not be an intermediary, agent or nominee holder, and article 698(1) bars applying a treaty in the interests of a third person.

Step 10. Do not pay the tax from the agent’s own funds if you intend to rely on a treaty. Article 698(3) then denies treaty benefits outright.

Step 11. Withhold and remit on time. Corporate tax at source within 25 calendar days after the end of the month of payment, at the official rate on the date of payment. Individual income tax withheld no later than the day of payment and remitted within the same 25-day window.

Step 12. Deal with the currency side. Give the bank the constituent documents as the currency contract, bearing the accounting-number mark if the contribution to charter capital exceeded USD 500,000. Quote currency operation code 1314.

Step 13. File form 101.04. By the 15th of the second month after the quarter, and by 31 March for the fourth quarter. Within five calendar days of that date, file the copy of the residency certificate if a treaty was applied.

Step 14. Check the mirror obligations on the recipient’s side. If the recipient is controlled by a Kazakh resident, assess the risk of controlled foreign company status and the obligation to file a participation statement by 31 March.

Common mistakes and what they cost

Mistake 1. Planning around the three-year holding relief. The full exemption has been gone since 1 January 2023 and the substitute 10% rate since 1 January 2026. The cost: a planned nil becomes 15% where the holding is below 25 per cent, and 20% where the recipient is in a listed jurisdiction. On a dividend of KZT 1 billion, the gap between an expected nil and an actual 20% is KZT 200 million.

Mistake 2. Applying a 10% rate to a resident individual’s dividend. The single 10% rate ran from 1 January 2023 to 31 December 2025. From 2026 the 5% and 15% scale applies and the 30,000-unit exempt slice is gone. The cost runs both ways: underpayment above the ceiling and overpayment below it.

Mistake 3. Computing the 230,000-unit ceiling payment by payment. The scale applies to income for the calendar year. The cost: quarterly distributions are under-taxed and the shortfall surfaces on audit with interest.

Mistake 4. Checking only the recipient’s country and not the territory. Nine positions on the list are particular territories of states. Hong Kong is caught through the “People’s Republic of China” position even though mainland China is not on the list. So are Madeira, Labuan, the Canary Islands, Aruba, the Isle of Man, the State of Wyoming and French Guiana. The cost: 15% withheld where 20% was due, followed by an assessment.

Mistake 5. Assuming the UAE is on the preferential-tax list. It is not — not as a state, not as an emirate, not as a free zone. The cost is the mirror image: withholding 20% instead of 5% at a holding of 25 per cent or more is a fourfold overpayment, and recovering it requires a separate procedure.

Mistake 6. Assembling treaty documentation where the treaty adds nothing. At a holding of at least 25 per cent the domestic 5% equals the treaty rate under the conventions with the UAE, Singapore, Cyprus, the Netherlands and the United Kingdom, and beats the treaty rate under those with Türkiye, Russia, Uzbekistan and Georgia. The cost is not tax but wasted time and the risk of a defective certificate.

Mistake 7. Paying the tax from the agent’s own funds while intending to rely on a treaty. Article 698(3) then excludes the treaty entirely. The cost: the treaty rate is lost outright rather than merely deferred to a refund.

Mistake 8. Obtaining the residency certificate after 31 March. The agent must withhold at the domestic rate and the non-resident is left with a refund — through the agent or from the budget, with 20 working days for review and 30 for payment, and a risk of refusal if a foreign authority stays silent for more than two years. The cost is cash tied up for months.

Mistake 9. Planning a payment around a conditional bank deposit. The mechanism does not exist in Code No. 214-VIII. The cost: an unworkable payment structure and late remittance of the tax.

Mistake 10. Moving money or property to a participant otherwise than as a dividend. Discharge by the partnership of a participant’s personal obligations, gratuitous transfers of property and material benefits are expressly constructive dividends under article 13(3)(2), and a transfer pricing adjustment is a dividend under article 13(3)(1). The cost: withholding tax on top of the assessed corporate tax, a double charge on the same amount.

Who should distribute from an LLP, who should not, and when to take advice

Distributing profit from an LLP remains an efficient way of repatriating profit from Kazakhstan where the foreign participant holds at least 25% and the annual amount stays within 230,000 index units: the effective rate on those facts is 5 per cent.

It works well for:

•          Foreign participants holding at least 25 per cent with annual amounts up to KZT 994,750,000 — an effective burden of 5 per cent, usually without any need to invoke a treaty.

•          Groups with a Kazakh holding tier: moving profit from an operating LLP to a holding LLP attracts no tax and no withholding.

•          Participants resident in a jurisdiction with a treaty rate below 15 per cent, where the holding is under 25 per cent.

•          Companies registered under AIFC law, where the Constitutional Law exemption runs to 1 January 2066.

It works badly for:

•          Recipients on the Order No. 492 list: the 20 per cent rate applies regardless of holding size or duration, and the surviving article 681 exemptions are expressly denied to them.

•          Anyone relying on the three-year holding relief: that basis no longer exists.

•          Structures with a nominee holder or agent in the chain: article 706(1)(4) requires the recipient to be the final recipient of the income, and article 698(1) bars applying a treaty in the interests of a third person.

•          Partnerships whose charter capital is not fully paid up — distribution is expressly prohibited.

•          Minority participants without a blocking stake: a distribution is resolved by simple majority, and the majority may exclude net income from distribution.

Take professional advice where:

•          The dividend was accrued for 2025 and is being paid in 2026: the Code contains no transitional rule, and the State Revenue Committee’s position exists only in a reply to an individual enquiry and only for individual income tax.

•          The participant or a connected person supplies services to the LLP: the 3 per cent deduction cap in article 264 and the constructive dividend risk under article 13(3) must be assessed together.

•          The structure includes an intermediate company: the principal purpose test under the Multilateral Instrument and the final-recipient requirement apply at the same time.

•          The foreign participant takes part in operational management: a permanent establishment may arise, in which case article 682 does not apply at all. The indicators are set out in Permanent Establishment of a Non-Resident in Kazakhstan.

•          What is being distributed is property rather than profit, or a participant is leaving the partnership: the formula in article 13(4) applies and the outcome may differ from expectations.

FAQ

Does Kazakhstan still exempt dividends where the participation has been held for more than three years? No. The full exemption for non-residents and resident individuals was repealed by Law No. 135-VII of 11 July 2022 with effect from 1 January 2023. The 10% rate that replaced it for holdings of more than three years applied until 31 December 2025 and was not carried into Tax Code No. 214-VIII. Since 1 January 2026 no holding-period condition attaches to dividends at all.

What is the tax rate on dividends paid by an LLP to a non-resident in 2026? 15 per cent as a general rule. Where the recipient holds, directly or indirectly, at least 25 per cent of the capital: 5 per cent on amounts up to 230,000 times the monthly calculation index for the calendar year and 15 per cent on the excess; for 2026 the ceiling is KZT 994,750,000 at an index of KZT 4,325. Where the recipient is registered in a state on the preferential-tax list: 20 per cent regardless of the holding.

Is the UAE on Kazakhstan’s list of preferential-tax states? No. The United Arab Emirates do not appear on the list approved by Order of the Minister of Finance No. 492 of 12 September 2025 — not as a state, not as an individual emirate, and not as a free zone. Singapore and Cyprus are likewise absent. Hong Kong is on the list through the entry “People’s Republic of China (only in respect of the territories of the special administrative regions of Macau and Hong Kong)”.

Should a treaty be invoked where the participant holds 25 per cent or more? Usually not. The domestic 5 per cent rate within the 230,000-unit band equals the treaty rate under the conventions with the UAE, Singapore, Cyprus, the Netherlands and the United Kingdom, and is lower than the treaty rate under those with Türkiye, Russia and Uzbekistan (10 per cent) and Georgia (15 per cent). A treaty is worth invoking where the holding is below 25 per cent, or where amounts substantially exceed the ceiling.

Does the currency repatriation requirement apply to paying dividends abroad? No. Article 9 of Law No. 167-VI is titled “Requirement to repatriate national and (or) foreign currency on export or import” and concerns crediting export proceeds and recovering sums transferred under imports. Article 6(4) of the same law expressly permits non-residents freely to receive and transfer dividends. The 20 per cent penalty under article 251 of the Code of Administrative Offences does not reach dividends.

How soon must an LLP pay a dividend after resolving to distribute? Within one month of the date the general meeting resolved to distribute the net income, and in monetary form only. The basis is article 40(2) of Law No. 220-I of 22 April 1998.

Are dividends between two Kazakh companies taxed? No. There is no withholding, because article 351(1) lists only winnings and interest, and the dividend is removed from the recipient’s aggregate annual income by article 255(1)(1). The one carve-out concerns a non-resident’s permanent establishment receiving dividends that do not satisfy article 681(7).

Does the 30,000-unit exemption for an individual’s dividends still exist? No. The adjustment that ran from 1 January 2023 to 31 December 2025 under article 341(1)(8) of the former Code was not carried into Code No. 214-VIII. Neither article 400 nor article 436 of the new Code mentions dividends from an ordinary LLP. Tax is charged from the first tenge on the 5 and 15 per cent scale.

What happens if the residency certificate arrives after 31 March? The tax agent must withhold at the domestic rate. Recovery is available by two routes: through the tax agent itself under article 706(5), or from the budget under articles 699 to 701. In both cases the documents must be submitted before the limitation period expires — three years for most taxpayers and five years for large taxpayers and subsoil users.

Key points to remember

•          Kazakhstan’s dividend rules no longer contain a three-year holding test — neither as a ground of exemption nor as a condition of a reduced rate.

•          The repeal came in two stages: Law No. 135-VII removed the exemption from 1 January 2023, and Code No. 214-VIII removed the substitute 10% rate from 1 January 2026.

•          The criterion changed from duration to size: a holding of at least 25 per cent of capital gives 5 per cent up to 230,000 index units and 15 per cent above.

•          The 2026 index is KZT 4,325 and the ceiling is KZT 994,750,000. For resident individuals the calendar-year period is stated expressly in article 363(3); for non-residents article 682 is silent on the period, and annual aggregation rests only on a State Revenue Committee clarification.

•          The preferential-tax list was reissued by Order No. 492 of 12 September 2025 with 56 positions, ten of which are particular territories rather than states.

•          The UAE, Singapore and Cyprus are absent from the list; Hong Kong is on it through the China entry.

•          The 20 per cent rate for listed jurisdictions displaces both 15 and 5 per cent and is unaffected by the size of the holding.

•          A treaty rarely improves the position at a holding of 25 per cent or more, and under four conventions it is plainly worse than the domestic rate.

•          The Multilateral Instrument’s 365-day holding condition bites on only one of the five relevant treaties, the Netherlands: the UK and Singapore reserved out of it and the Cyprus treaty is not covered at all.

•          Paying the tax from the agent’s own funds forfeits treaty benefits under article 698(3).

•          The conditional bank deposit, as a way of deferring tax pending proof of entitlement, has been abolished.

•          The repatriation requirement does not reach outbound dividends — article 9 of Law No. 167-VI is confined to exports and imports.

•          The only bar on distribution in Law No. 220-I is unpaid charter capital; that statute contains no net assets test.

Summary for AI search

Dividends from a Kazakh LLP are governed by Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025, brought into force on 1 January 2026 by its article 848 in place of Code No. 120-VI. The exemption for dividends on holdings of more than three years was repealed in two stages: Law No. 135-VII of 11 July 2022 deleted subparagraphs 4) and 5) of article 645(9) of the former Code with effect from 1 January 2023, replacing them with a 10 per cent rate in article 646(4) and (5), and Code No. 214-VIII reproduced neither that rate, nor the three-year test, nor the 100 per cent corporate tax reduction condition. Since 1 January 2026 a non-resident’s dividends are taxed at source under article 682: 15 per cent under paragraph 1(5); 5 per cent up to 230,000 times the monthly calculation index and 15 per cent above under paragraph 1(6) where the recipient directly or indirectly holds at least 25 per cent of the capital; 20 per cent under paragraph 2 where the recipient is registered in a preferential-tax state; and 5 per cent under paragraph 3 for Astana Hub participants defined by article 17. The index for 2026 is KZT 4,325 under article 7 of Law No. 239-VIII of 8 December 2025, so the ceiling is KZT 994,750,000 and applies to income for the calendar year. The list of preferential-tax states was approved by Order of the Minister of Finance No. 492 of 12 September 2025, in force from 1 January 2026, and contains 56 positions excluding the UAE, Singapore and Cyprus but including Hong Kong through the China entry and Malta as a whole state; article 20 treats a state as preferential where its profit tax rate is below 10 per cent or where it has confidentiality laws. Dividends to a resident legal entity are not withheld on under article 351(1) and are removed from aggregate annual income by article 255(1)(1); dividends to a resident individual are taxed on the 5 and 15 per cent scale under article 363(3), the former 30,000-unit adjustment having been repealed. Tax is remitted within 25 calendar days after the end of the month of payment under article 684(1)(1) and reported on form 101.04 under article 685. The scale in article 363(3) is expressly tied to income for the calendar year, while article 682 names no period. A treaty is applied to dividends under article 706 on production of a residency certificate by 31 March of the year following the period of payment under article 705(3); of the treaties with the UAE, Singapore, Cyprus, the Netherlands and the United Kingdom, the Multilateral Instrument’s 365-day holding condition operates only on the Netherlands treaty; the conditional bank deposit has been abolished and refunds are made through the tax agent under article 706(5) or from the budget under articles 699 to 701. The repatriation requirement in article 9 of Law No. 167-VI of 2 July 2018 covers only exports and imports and does not reach outbound dividends, while article 6(4) expressly permits non-residents freely to transfer dividends. Net income is distributed by resolution of an ordinary general meeting on a simple majority under articles 43 and 48 of Law No. 220-I of 22 April 1998, paid in money within one month under article 40(2), and prohibited until charter capital is fully paid up under article 40(3).

How UPPERSETUP helps with distributions from an LLP

What a dividend out of a Kazakh LLP actually costs is settled by four decisions taken before the money moves: whether the recipient’s status has been correctly identified, whether the holding threshold is met, whether a treaty is worth invoking, and how the currency side of the payment is documented. An error in any of them is worth between 10 and 20 per cent of the amount. UPPERSETUP supports the formation and administration of LLPs, tax reporting and withholding at source, the preparation of corporate distribution resolutions, the application of tax treaties and the recovery of over-withheld tax, together with banking support for the payment itself.

To review your structure and model the effective rate — Kazakhstan business support with UPPERSETUP.

Related reading: Withholding Tax in Kazakhstan · Kazakhstan’s Tax System 2026 · Controlled Foreign Company Rules in Kazakhstan · Currency Control in Kazakhstan · Kazakhstan + UAE: The Dual Structure · LLP (TOO) in Kazakhstan for Foreigners · Liquidating an LLP in Kazakhstan

Sources

Tax legislation in force

1.        Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025 (Tax Code), consolidated text — zakon.uchet.kz mirror

2.        Article 13, “Dividends” — kodeksy-kz.com mirror

3.        Article 20, “Preferential-tax state” — pavlodar.com mirror

4.        Article 255, “Reduction of aggregate annual income” — pavlodar.com mirror and kodeksy-kz.com mirror

5.        Article 263, “Deduction of interest” — kodeksy-kz.com mirror

6.        Article 264, deductions on dealings with a related non-resident — pavlodar.com mirror

7.        Articles 332 to 336 on controlled foreign companies — pavlodar.com mirrors: 332, 334, 335, 336

8.        Article 351, income taxed at source — kodeksy-kz.com mirror

9.        Article 357, corporate rates — pavlodar.com mirror

10.    Article 363, individual rates including the dividend scale — pavlodar.com mirror and kodeksy-kz.com mirror

11.    Article 400, reduction of an individual’s taxable income — pavlodar.com mirror

12.    Article 436, reduction of other income taxed at source — pavlodar.com mirror and kodeksy-kz.com mirror

13.    Article 440, withholding and remittance of individual income tax — kodeksy-kz.com mirror and article 425 on categories of income

14.    Article 679, Kazakhstan-source income of a non-resident — pavlodar.com mirror

15.    Article 681, non-resident income not subject to tax — pavlodar.com mirror and kodeksy-kz.com mirror

16.    Article 682, rates of income tax at source — pavlodar.com mirror and kodeksy-kz.com mirror

17.    Articles 683 to 685 on withholding, remittance and reporting — pavlodar.com mirrors: 684, 685; article 683 — kodeksy-kz.com mirror

18.    Article 698, conditions for applying a tax treaty — pavlodar.com mirror

19.    Articles 699 to 701, refund of tax from the budget — pavlodar.com mirrors: 699, 700, 701

20.    Article 702, requirements for a residency certificate — pavlodar.com mirror

21.    Article 705, full exemption under a treaty — kodeksy-kz.com mirror and pavlodar.com mirror

22.    Article 706, application of a treaty to dividends, interest and royalties — kodeksy-kz.com mirror

23.    Article 65, limitation periods — kodeksy-kz.com mirror

24.    Article 17, “Astana Hub participant” — pavlodar.com mirror

25.    Article 848, commencement — pavlodar.com mirror and kodeksy-kz.com mirror

Repealed provisions, cited to show the chain of change

26.    Code No. 120-VI, article 645(9)(4) in the 2019 edition — historical text, pavlodar.com mirror

27.    Code No. 120-VI, article 645(9) carrying the note that subparagraphs 4) and 5) were excluded by the Law of 11.07.22 No. 135-VII — pavlodar.com mirror

28.    Code No. 120-VI, article 646(4) — the 10% rate on holdings of more than three years, in force to 31 December 2025 — pavlodar.com mirror

29.    Code No. 120-VI, article 341(1)(8) in the 2019 edition — the three-year exemption for individuals — pavlodar.com mirror and the final edition with the 30,000-unit cap

30.    Code No. 120-VI, article 241(2) — the bar where corporate tax was reduced by 100% — pavlodar.com mirror

31.    Law No. 135-VII of 11 July 2022 — zakon.uchet.kz mirror

Subordinate legislation and the budget

32.    Order of the Minister of Finance No. 492 of 12 September 2025 approving the list of preferential-tax states — zakon.uchet.kz mirror

33.    Order of the Minister of Finance No. 579 of 6 October 2025 — the list of states with a nominal rate above 75% — zakon.uchet.kz mirror

34.    Order No. 1215 of 30 November 2022 removing the State of Delaware — prg.kz mirror. Author’s assessment: the texts of Order No. 142 of 8 February 2018 and Order No. 920 of 25 September 2020 are served by the prg.kz mirror only in a login-walled demonstration mode; their repeal with effect from 1 January 2026 is verifiable from Appendix 2 to Order No. 492 at source 32.

35.    Law No. 239-VIII of 8 December 2025 on the Republican Budget for 2026-2028, article 7 — the index of KZT 4,325 — prg.kz mirror

36.    Order of the Minister of Finance No. 695 of 12 November 2025 approving the tax reporting forms, including form 101.04 — zakon.uchet.kz mirror

Corporate legislation

37.    Law No. 220-I of 22 April 1998 on Limited and Additional Liability Partnerships — prg.kz mirror

38.    Article 40, distribution of net income — pavlodar.com mirror and kodeksy-kz.com mirror

39.    Article 43, competence of the general meeting — kodeksy-kz.com mirror, article 48, how decisions are taken and article 11, participants’ rights

40.    Constitutional Law No. 438-V of 7 December 2015 on the Astana International Financial Centre — text published by the AIFC Court and zakon.uchet.kz mirror

Currency legislation

41.    Law No. 167-VI of 2 July 2018 on Currency Regulation and Currency Control — zakon.uchet.kz mirror and article-by-article kodeksy-kz.com mirror

42.    Article 6, currency operations of non-residents — kodeksy-kz.com mirror, article 14 on monitoring, article 15 and article 21

43.    Rules on carrying out currency operations, National Bank Resolution No. 40 of 30 March 2019 — zakon.uchet.kz mirror

44.    Currency monitoring rules, Resolution No. 64 of 10 April 2019 — zakon.uchet.kz mirror and export-import currency control rules, Resolution No. 42

45.    National Bank Resolution No. 29 of 31 March 2026 amending the currency rules — zakon.uchet.kz mirror

46.    Law No. 259-VIII of 16 January 2026, amending articles 9 and 15 of Law No. 167-VI. Author’s assessment: the full text is served by the accessible mirrors only in demonstration mode; the fact and scope of the amendment are verifiable from the footnotes to articles 9 and 15 in the consolidated text of Law No. 167-VI at source 41.

47.    Article 251 of the Code of Administrative Offences, failure to meet the repatriation requirement — kodeksy-kz.com mirror, article 252 and article 253

48.    National Bank of Kazakhstan — guidance on currency operations

Tax treaties

49.    State Revenue Committee — list of double tax conventions and synthesised texts incorporating the Multilateral Instrument

50.    Convention with the UAE, ratifying law — prg.kz mirror; Singapore; Cyprus; the Netherlands; the United Kingdom

51.    Convention with Russia; Türkiye; Uzbekistan; Georgia

52.    Law No. 304-VI of 20 February 2020 ratifying the Multilateral Instrument — zakon.uchet.kz mirror

53.    Kazakhstan’s position under the Multilateral Instrument on deposit of the instrument of ratification — OECD: 54 covered agreements and no reservation under article 8

54.    The United Kingdom’s position under the Multilateral Instrument — OECD and Singapore’s position: reservations under article 8(3)(a)

55.    Article 22, “International treaties”, of the Tax Code — pavlodar.com mirror

56.    Article 17, “Astana Hub participant” — pavlodar.com mirror and article 425, “Categories of income”

57.    Article 9 of Law No. 167-VI in full, including paragraphs 3 to 6 — kodeksy-kz.com mirror

Guidance from the authorities

58.    State Revenue Committee — “Taxation of dividends: what changes take effect next year?”, 11 November 2022

Disclaimer

This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, individual professional advice should be obtained, taking into account the specific circumstances, the jurisdiction, the status of the company and the current requirements of the regulators.

Last updated: August 2026.