Withholding Tax in Kazakhstan 2026: Services, Royalties, Interest, Dividends, the Residency Certificate and Treaty Relief

Kazakhstan withholding tax is deducted by the Kazakhstan payer from a foreign company's income sourced in the Republic of Kazakhstan, with no deductions allowed. The headline rate is 20 per cent; dividends, royalties and interest carry 15 per cent; interest on loans and debt securities carries 10 per cent; international transport services carry 5 per cent. The framework from 1 January 2026 is Division 15 of the new Tax Code (Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025), articles 679 to 687 and chapter 75.

The costliest misreading is that services performed outside Kazakhstan escape the tax. Article 679(1)(3) treats management, consultancy, engineering, marketing, audit, design, advertising, legal and financial services, and information-processing services, as Kazakhstan-source income even when performed entirely abroad. For that list, the place of performance is irrelevant.

What changed on 1 January 2026

The new Code rewrote the rate scale and added a self-contained set of rules on financial loans. Four changes matter to a payer.

●      Dividends acquired a progressive scale for substantial shareholders: where the recipient holds, directly or indirectly, at least 25 per cent of the capital, 5 per cent applies up to 230,000 times the monthly calculation index (MCI) and 15 per cent to the excess.

●      Interest was split by type: loans, credits and debt securities carry 10 per cent; other interest carries 15 per cent.

●      A financial loans block was introduced (article 679(1)(39)): unrepaid principal and certain loan-related payments are treated as Kazakhstan-source income of the non-resident.

●      For persons registered in a state with preferential taxation the rate remains 20 per cent across the board, and their works and services are taxed regardless of where they are performed.

The MCI for 2026 is KZT 4,325, so the 230,000 MCI dividend threshold equals KZT 994,750,000. The index in force on 1 January of the relevant financial year applies.

The legal framework

The whole mechanism sits in Division 15 of the Code, with its elements spread across separate articles.

Element	Provision	What it sets
Kazakhstan-source income	Article 679	39 categories of income that trigger the tax
Exclusions	Articles 680 and 681	Amounts that are not income and income not subject to tax
Rates	Article 682	20%, 15%, 10%, 5% and the progressive dividend scale
Computation and withholding	Article 683 (chapter 72)	Who is the agent, when to withhold, royalties and mixed contracts
Remittance deadlines	Article 684	25 calendar days, plus special rules for loans
Reporting	Article 685	Filing deadlines for the calculation
Capital gains	Article 687	The separate regime for property, shares and participations
Treaty relief	Chapter 75, articles 698–714	Conditions, procedure and residency certificate requirements

The first question: is there Kazakhstan-source income

The tax arises only if the payment falls within the list in article 679. The list is structurally closed but broad in reach: 39 categories, ending with an open-ended reference to other income arising from activity in Kazakhstan.

●      Sale of goods in Kazakhstan, and sale of goods located in Kazakhstan for export within foreign trade activity.

●      Works and services performed in Kazakhstan — the general place-of-performance rule.

●      A separate list of services taxed regardless of place (subparagraph 3), analysed below.

●      Passive income: dividends from a resident, interest, royalties, rental of property in Kazakhstan, income from Kazakhstan real estate.

●      Special categories: insurance premiums, international transport, demurrage, operation of pipelines and communication lines, assignment of claims, penalties and fines.

"Payment of income" covers not only transfers of money but also transfers of securities, participations, goods and property, the performance of works and services, and the write-off or set-off of a debt claim. Absent an actual payment, state registration of the acquired property counts as payment.

A set-off of mutual claims is a payment of income for these purposes. "We paid no money, so nothing to withhold" is wrong: the agent's obligation crystallises at the moment of set-off.

Services taxed regardless of where they are performed

Article 679(1)(3) identifies services whose income is Kazakhstan-source even where the service was rendered entirely abroad.

Type of service	Taxed when performed abroad
Management, consultancy, engineering	Yes
Marketing, advertising, design	Yes
Audit, financial services, information processing	Yes
Legal — except representation and defence in courts, arbitration or tribunals, and notarial services	Yes, save for those carved out
Other works and services outside the list	No, where performed outside Kazakhstan

"Financial services" here means the activity of insurance and securities market participants, of accumulative pension funds, banking activity, the activity of the central depository and mutual insurance societies, and the activity of the social health insurance and social insurance funds.

For a Kazakhstan company the practical consequence is direct: engaging a foreign consultant, marketing agency or auditor creates a withholding obligation even where the provider never sets foot in Kazakhstan. Reviewing the pattern of payments to non-residents belongs alongside the bookkeeping function — the work of UPPERSETUP accounting services.

States with preferential taxation: a separate regime

Two reinforcing rules apply to persons registered in a state with preferential taxation.

●      Under article 679(1)(4) such a person's income from works and services is Kazakhstan-source regardless of where they are actually performed, alongside its other income under that article.

●      Under article 682(2) such a person's income is taxed at 20 per cent — without the reduced rates otherwise available for dividends, interest and royalties.

The list in force was approved by Order of the Minister of Finance of the Republic of Kazakhstan No. 492 of 12 September 2025 and took effect on 1 January 2026. It covers 56 states and territories, unchanged in composition from the previous edition.

The list includes the Chinese special administrative regions of Hong Kong and Macau, along with jurisdictions rarely thought of as offshore: the Kingdom of Bahrain, Montenegro, the Philippines, the Canary Islands within Spain and certain French territories. A payment to a Hong Kong company for services therefore attracts the 20 per cent rate and the place-irrelevant rule — a regular surprise for groups with a Hong Kong arm.

The test sits in article 20 of the Code: an income tax rate in that state below 10 per cent, or laws on the confidentiality of financial information that allow the beneficial owner to be kept secret. The second limb does not apply to states with which Kazakhstan has a treaty providing for exchange of information between competent authorities.

Two carve-outs apply to subparagraph 4: income from tourist services provided to an individual within that state, and income from airport activity as defined by Kazakhstan law.

The 20 per cent rate under article 682(2) attaches to the income as such. Whether a double tax treaty applies is a separate question decided on its own rules — but Kazakhstan has no treaty in force with most jurisdictions on the preferential-taxation list.

The rate table

Rates are set by article 682 and apply to the income defined in article 679, other than income listed in article 681.

Type of income	Rate
Income under article 679 other than the categories below	20%
Insurance premiums under risk insurance contracts	15%
Insurance premiums under reinsurance contracts	5%
International transport services	5%
Capital gains, dividends, interest, royalties — except the two entries below	15%
Dividends to a holder of at least 25% of capital, directly or indirectly	5% up to 230,000 MCI; thereafter the tax on 230,000 MCI plus 15% on the excess
Interest on credits (loans) and debt securities	10%
Gambling and betting winnings	10%
Income of a person registered in a state with preferential taxation	20%

A separate 5 per cent rate is set by article 682(3) for capital gains on the disposal of shares and participations in the legal entities referred to in article 17 of the Code, and for dividends received from those entities.

Article 682 does not apply to a non-resident operating in Kazakhstan through a permanent establishment— chapter 73 governs that case instead. Distinguishing a payment to a non-resident without a permanent establishment from activity through one is a threshold question, settled before any rate is chosen.

Dividends: why the larger shareholder pays less

The base rate on dividends is 15 per cent, but a shareholder holding at least 25 per cent benefits from a progressive scale starting at 5 per cent.

Taxable income	Rate
Up to 230,000 MCI inclusive — KZT 994,750,000 in 2026	5%
Above 230,000 MCI	Tax on 230,000 MCI plus 15% on the excess

The holding may be direct or indirect — the scale reaches a parent holding its stake through intermediate entities.

The reduced dividend scale does not displace the preferential-taxation test: a person registered in such a state falls under article 682(2) and the 20 per cent rate.

Royalties and the technical support trap

Royalty income is taxed at 15 per cent. Amounts for support and technical assistance are not royalties — but on one condition only.

Under article 683(5), amounts for support services and technical support services are not taxed as royalties provided they are stated separately from the royalty amount. Absent that separation, the entire amount of the non-resident's income is taxed as royalties.

This is a drafting rule, not a computation rule. A single invoice line reading "licence and support — USD X" means the whole sum will be characterised as royalties. The split must exist in the contract and the primary documents, not appear in correspondence after the event.

Drafting with foreign software vendors and rights holders is the province of UPPERSETUP legal services: the cost of error here is set by characterisation of the whole payment, not by the rate.

Mixed contracts: work inside and outside Kazakhstan

Where a contract provides for works and services both inside Kazakhstan and abroad, the withholding rules apply to each type of work and service separately.

1.   Each stage of work within a single production and technological cycle counts as a separate type of work or service.

2.  The total income under the contract must be reasonably allocated between work in Kazakhstan and work abroad.

3.  The non-resident must supply the recipient with copies of accounting records, prepared under Kazakhstan and/or foreign law, evidencing that allocation.

The sanction for failing to allocate is severe. Where there is no allocation, or the allocation is unjustified and understates the taxable amount, the aggregate income under the contract is taxed — including the portion attributable to work performed abroad. The non-resident's accounting records become the condition for the saving, not a formality.

Unearned advances and unpaid deliveries

Two categories of income arise not from a payment but from its absence, and they are routinely overlooked.

●      Article 679(1)(5): a non-resident's obligations under an advance received that remain unsatisfied for twelve months from the date the advance was paid become its Kazakhstan-source income. The same applies as at the date of the liquidation return where the payer of the advance is being wound up.

●      Subparagraph 6: obligations to pay a resident for goods, works or services delivered that the non-resident leaves unsatisfied for twelve months from delivery likewise become income.

Where the non-resident later performs in full, the agent may amend the return already filed, and any overpaid tax may be offset or refunded.

In practice: an undelivered order against a year-old advance turns into a tax liability of the Kazakhstan company. Monitoring the ageing of advances is a tax function, not only a treasury one.

Financial loans: a new set of rules

Article 679(1)(39) treats a series of loan-related situations, other than bank loans, as Kazakhstan-source income of the non-resident.

●      Unrepaid or partly unrepaid principal on a loan repayable within twenty-four months, measured against the loan's terms. Where a repayment schedule exists, each missed instalment counts as income.

●      Unrepaid principal on a loan repayable in more than twenty-four but no more than sixty months.

●      Principal on a loan repayable in more than sixty months.

●      Payments by a resident to repay a loan credited to an account with a foreign bank outside Kazakhstan, and payments made to advance a loan to a non-resident repayable to such an account.

●      An amount computed by applying the average market rate to a payment advancing an interest-free loan to an unaffiliated non-resident.

"Financial loan" carries the meaning given in the Law of the Republic of Kazakhstan on currency regulation and currency control.

Remittance deadlines for this income sit in article 684(2) and key off the repayment date, the advance of the loan or the payment itself. How this interacts with the currency perimeter is covered in Currency Control in Kazakhstan 2026, while settlement and banking procedures sit with UPPERSETUP banking services.

Who withholds, and when

The obligation and the liability rest on the person paying the income who qualifies as a tax agent. The list is closed.

●      An individual entrepreneur.

●      A non-resident legal entity operating in Kazakhstan through a structural subdivision, or through a permanent establishment without opening one.

●      A resident legal entity, including the issuer of the underlying asset of depositary receipts.

●      A person paying capital gains income; in defined cases an individual also qualifies as a tax agent.

Computation and withholding are performed no later than the day the income is paid for accrued and paid income, and no later than the deadline for the income tax return for accrued but unpaid income taken as a deduction.

Tax is withheld regardless of the form and place of payment, and regardless of how the non-resident disposes of the income in favour of third parties or of its own subdivisions in other states. Paying from a foreign account into a foreign account changes nothing.

Payment and filing deadlines

Situation	Remittance deadline
Accrued and paid income	No later than 25 calendar days after the end of the month of payment, at the rate on the payment date
Accrued but unpaid income taken as a deduction	No later than 10 calendar days after the deadline for the corporate income tax return
Payment of an advance	No later than 25 calendar days after the end of the month of accrual, within the advance
Delivery of goods, works or services by the resident	No later than 25 calendar days after the end of the month of accrual, within the obligation

Reporting period	Filing deadline
First, second and third quarters	No later than the 15th of the second month following the quarter of payment
Fourth quarter	No later than 31 March of the year following the reporting tax period

Remittance is made by the agent at its place of location, and the calculation is filed with the tax authority at that same location.

Treaty relief: conditions and the anti-abuse rule

A treaty applies to persons who are residents of one or both contracting states, and the manner of application is governed by the Code together with the treaty itself.

The key limitation in article 698: the provisions do not apply to a resident of the partner state where that resident uses the treaty in the interests of another person who is not a resident of that state. This is a direct anti-conduit rule, and it operates whether or not a residency certificate is in hand.

Where a treaty has been modified by the multilateral instrument on base erosion and profit shifting, it applies as modified. What must be checked is not the bilateral text in isolation but its version as amended by the MLI.

A rule that defeats a popular arrangement. Under article 698(3), where the tax agent pays the tax from its own funds without withholding from the non-resident's income, the treaty provisions do not apply at all. The bargain "we will bear the tax and you will apply the treaty rate" is legally unavailable.

Applying a treaty as the tax agent

The article 705 procedure is not universal. It covers income under article 679 except income for which a different procedure is set by articles 706, 707, 712, 713 and 714, capital gains under article 687, and income from services where a registered structural subdivision or permanent establishment exists. Dividends, interest and royalties — most passive payments, in other words — run through article 706 with additional conditions.

Under article 705 the agent may apply an exemption itself, at the point of payment or when taking accrued but unpaid income as a deduction, on two conditions: a treaty with the state of residence has been concluded and ratified, and the residency document has been provided within the statutory window.

The residency document must be given to the agent by the earlier of two dates: 31 March of the year following the tax period in which the income was paid or taken as a deduction, or no later than five working days before a tax audit of withholding obligations concludes.

Where the non-resident performs services in Kazakhstan within a period that does not create a permanent establishment, it must also provide notarised copies of constitutional documents or an extract from the commercial register naming founders and majority shareholders. Where neither exists, the document establishing the non-resident, or a document setting out the group's organisational structure, is accepted instead.

The tax agent must file a copy of the residency document with the tax authority no later than five calendar days after the filing deadline for the fourth-quarter return.

The article 705 procedure does not extend to four categories, including income from services and works within one project or connected projects that create a permanent establishment. The agent determines connectedness itself under article 228 — and that is where disputes most often begin.

Dividends, interest and royalties: the four conditions of article 706

For these three income types the agent may apply a treaty on its own initiative only where four conditions are met simultaneously — two more than under the general article 705 route.

1.   A treaty with the state of residence has been concluded and ratified.

2.  The residency document has been provided within the article 705(3) window and meets the requirements of article 702.

3.  The income paid is not connected with the activity of a permanent establishment of the non-resident in Kazakhstan.

4.  The non-resident is the final recipient of the income.

The Code defines the final recipient as the person — the beneficial owner — holding the rights of ownership, use and disposal of the income and not acting as an intermediary in respect of it, including as an agent or nominee holder.

This is a beneficial ownership test written into domestic law, not merely into the treaty text. The tax agent applies it before granting the reduced rate, and the burden of establishing final-recipient status rests on the Kazakhstan side.

Interest paid through an intermediary

Where interest reaches the final recipient through an intermediary, the reduced rate or exemption applies only where two requirements are met together.

●      The contract under which the interest is paid states the intermediary's name, the amounts paid to it, the interest attributable to each final recipient, the identifying details of the intermediary and of that person, and their tax and state registration numbers in the country of incorporation.

●      The residency document of the final recipient is provided within the article 705(3) window and meets article 702.

Requiring the payment structure to appear in the contract itself is not a formality: without those particulars in the text, the reduced rate is unavailable even where the beneficial owner is obvious from correspondence.

Refunds are made by the agent, not by the budget

Where the tax has already been withheld and remitted, the final recipient may recover the excess under the treaty. The refund is made by the tax agent, not by the tax authority.

1.   The non-resident gives the agent a notarised copy of the contract with the intermediary showing the amounts and identifying particulars, together with a residency document for the period in which the income was accrued.

2.  Those documents must be provided before the limitation period expires, running from the date the withheld tax was last remitted, unless the treaty sets a different period.

3.  Having made the refund, the agent may file an additional calculation for the amount of the reduction and obtain an offset of the overpaid tax.

Dividends on shares underlying depositary receipts run through yet another self-contained procedure — article 707 — which requires a list of receipt holders compiled by the central depository or by a foreign depository organisation.

The copy of the final recipient's residency document goes to the tax authority on the same timetable — no later than five calendar days after the deadline for the fourth-quarter return.

The residency certificate: three acceptable forms

Article 702 sets the requirements. The residency document is an official document of the competent foreign authority, produced in one of three forms.

1.   An original certified by the competent authority, with the official's signature and the authority's seal legalised under Kazakhstan law — or with the legalising document published on the website of the legalising body or of another organisation holding electronic apostilles.

2.  A notarised copy of such an original, with the foreign notary's signature and seal legalised on the same terms.

3.  A paper copy of an electronic document published on the website of the competent foreign authority.

Where the competent authority's website carries an abridged version of the paper copy of the electronic document, but it confirms residency, that document qualifies for the period stated.

Legalisation is not required where the document is published on the competent authority's website, or where a different method of authentication is set by a Kazakhstan treaty, by agreement between competent authorities under the mutual agreement procedure, or by a decision of an EAEU body.

What period a certificate covers

What the document states	Period of recognised residency
A period of time is stated	That stated period
Residency confirmed as at a given date	From the start of the calendar year to that date
No period stated	The calendar year in which the document was issued or published

Hence a practical rule: a certificate confirming residency "as at 15 June" does not cover payments made in the second half of the year. For payments spread across a year, obtain a document stating an express period, or a fresh certificate.

If the tax has already been withheld in full

Where the agent did not apply a treaty, the non-resident may claim a refund from the budget. Article 699 governs the application, article 700 its consideration and decision, and article 701 the appeal.

Where the agent does not apply the treaty, it must withhold and remit the tax — declining to apply a treaty does not discharge the obligation.

Where a treaty is applied improperly, resulting in non-remittance or partial remittance of withheld amounts, the tax agent bears the liability prescribed by Kazakhstan law. The risk of error sits with the Kazakhstan side, not with the non-resident.

Step-by-step for a Kazakhstan company

1.   Characterise the payment under article 679: does Kazakhstan-source income arise, and under which subparagraph.

2.  Check the exclusions in articles 680 and 681 before reaching for a rate.

3.  Check the recipient's status: whether it is registered in a state with preferential taxation, which changes both scope and rate.

4.  Test for a permanent establishment — if one exists, chapter 73 applies instead of withholding.

5.  Select the rate under article 682, taking account of the income type and, for dividends, the size of the holding.

6.  Test the contract for mixed scope and require the non-resident's accounting records allocating work inside and outside Kazakhstan.

7.  Check that royalties and support services are separated in the contract and the invoice.

8.  Request the residency certificate early, with an express period stated, and test it against article 702.

9.  Withhold and remit within the article 684 deadlines, or apply the treaty under article 705.

10.      File the calculation within the article 685 deadlines and the certificate copy within five calendar days after the fourth-quarter deadline.

Building the process for dealing with non-residents — from contract templates to certificate control — sits alongside incorporation and corporate services: UPPERSETUP, with the full catalogue in the services section.

Common mistakes and what they cost

Assuming offshore-performed services are outside the charge

Management, consultancy, engineering, marketing, audit, design, advertising, legal and financial services, and information processing, are taxed regardless of place. A contract with a European consultant who never visits Kazakhstan produces 20 per cent withholding unless a treaty is applied.

Failing to separate royalties from technical support

Without the split, the entire amount is taxed as royalties. The separation must appear in the contract and the primary documents; it cannot be reconstructed after an audit.

Not obtaining the non-resident's records on a mixed contract

Without a justified allocation, the aggregate contract value is taxed, including work performed abroad. The obligation to produce the records is the non-resident's; the consequence falls on the tax agent.

Accepting a residency certificate without checking its period

Confirmation as at a specific date covers only the period from the start of the calendar year to that date, and a document with no stated period covers only its year of issue. Payments outside the covered period have no basis for relief.

Applying the article 705 route to dividends and royalties

Article 705 expressly excludes income governed by articles 706 and 707. Dividends, interest and royalties require two further tests: no connection with a permanent establishment, and final-recipient status. Applying the general route to passive payments amounts to improper application of the treaty, with the consequences that follow.

Paying the tax from the company's own funds and expecting the treaty rate

Under article 698(3) the treaty then does not apply at all. The agent's obligation is treated as discharged, but the reduced rate is lost.

Overlooking advances and unsatisfied obligations

An advance the non-resident has not worked off within twelve months, and a resident's delivery it has not paid for within the same period, both become Kazakhstan-source income. Tax arises with no payment being made at that moment.

Not filing the certificate copy with the tax authority

Beyond obtaining the certificate from the non-resident, the agent must send a copy to the tax authority within five calendar days after the fourth-quarter filing deadline. That is a standalone obligation, not a duplicate.

Which approach fits which situation

Situation	Working approach	Watch item
One-off advice from a foreign expert	Withhold 20% or apply a treaty	Residency certificate by 31 March of the following year
Software licence bundled with support	Split the amounts in the contract	Otherwise the whole sum is royalties at 15%
Dividends to a parent holding 25% or more	The 5% and 15% progressive scale	The 230,000 MCI threshold and the preferential-taxation test
Intra-group loan	Test article 679(1)(39)	The 24-month and 60-month repayment marks
Contractor working both in and outside Kazakhstan	Separate accounting by type of work	The non-resident’s accounting records
Counterparty in a preferential-taxation jurisdiction, including Hong Kong and Macau	20% across all income	Place of performance is irrelevant; the list is set by Order No. 492

For structures pairing a Kazakhstan company with a foreign one, see Kazakhstan + UAE: the Dual Structure in 2026 and Controlled Foreign Company Rules in Kazakhstan.

When professional review is warranted

●      The contract covers work both inside and outside Kazakhstan.

●      Payments run to a jurisdiction on the preferential-taxation list.

●      A foreign contractor works across several connected projects in succession.

●      The group holds intra-group loans that are interest-free or on unusual terms.

●      Dividends are paid to a shareholder holding around 25 per cent.

●      The residency certificate arrives in electronic or abridged form.

Frequently asked questions

Is withholding required where the service was performed outside Kazakhstan?

For management, consultancy, engineering, marketing, audit, design, advertising, legal and financial services, and information processing — yes, regardless of place. For other works and services, tax arises only where they were performed in Kazakhstan.

What is the withholding rate on a non-resident's services?

20 per cent as the general rate for income under article 679 that falls outside the special categories. For a person registered in a state with preferential taxation, also 20 per cent, but without the reduced rates for dividends, interest and royalties.

What rate applies to dividends paid to a non-resident in 2026?

15 per cent as the base rate. Where the recipient holds at least 25 per cent of the capital, directly or indirectly, 5 per cent applies up to 230,000 MCI and 15 per cent to the excess.

What rate applies to interest on a loan from a foreign company?

10 per cent for interest on credits, loans and debt securities. Other interest is taxed at 15 per cent.

By when must the residency certificate be obtained?

By the earlier of 31 March of the year following the tax period of payment, or five working days before a tax audit of withholding obligations concludes.

Can the treaty be applied if the company bears the tax itself?

No. Where the agent pays the tax from its own funds without withholding it from the non-resident's income, the treaty provisions do not apply.

What happens if royalties and support are not separated?

Amounts for support and technical support escape royalty treatment only when stated separately from the royalty. Without that separation, the entire amount of the non-resident's income is taxed as royalties.

When is the withholding calculation filed?

For the first, second and third quarters, by the 15th of the second month following the quarter of payment. For the fourth quarter, by 31 March of the following year.

Key takeaways

●      Tax is withheld with no deductions and regardless of the form or place of payment.

●      The list of services in article 679(1)(3) is taxed regardless of where performed.

●      Rates: 20% general, 15% dividends and royalties, 10% loan interest, 5% international transport.

●      Dividends to a 25%+ shareholder: 5% up to 230,000 MCI, then 15% on the excess.

●      A mixed contract without a justified allocation is taxed in full.

●      Residency certificate by 31 March of the following year; a copy to the tax authority within five days of the fourth-quarter deadline.

●      Dividends, interest and royalties run through article 706: no connection with a permanent establishment, and final-recipient status, are additional conditions.

●      Paying the tax from the agent's own funds forfeits treaty relief.

Summary

Kazakhstan withholding tax is deducted by a tax agent from a non-resident's Kazakhstan-source income with no deductions allowed, under Division 15 of Tax Code No. 214-VIII of 18 July 2025. Article 679 lists 39 categories of such income, including works and services performed in Kazakhstan and, regardless of place of performance, management, consultancy, engineering, marketing, audit, design, advertising, legal and financial services and information-processing services. Article 682 sets the rates: 20 per cent generally, 15 per cent on risk insurance premiums and on capital gains, dividends, interest and royalties, 10 per cent on interest from credits, loans and debt securities, and 5 per cent on reinsurance premiums and international transport services. Dividends paid to a person holding at least 25 per cent of the capital, directly or indirectly, attract a progressive scale of 5 per cent up to 230,000 times the monthly calculation index — KZT 994,750,000 at the 2026 index of KZT 4,325 — and 15 per cent on the excess. Income of a person registered in a state with preferential taxation is taxed at 20 per cent, and its works and services are Kazakhstan-source regardless of where performed. Tax is remitted no later than twenty-five calendar days after the end of the month of payment, and the calculation is filed by the 15th of the second month after the first, second and third quarters and by 31 March of the following year for the fourth quarter. To apply a double tax treaty, the non-resident gives the agent a residency document meeting article 702 no later than 31 March of the year following the tax period of payment, or five working days before a tax audit concludes. Dividends, interest and royalties follow the separate route in article 706: beyond a ratified treaty and a residency certificate, the income must not be connected with the activity of a permanent establishment in Kazakhstan and the non-resident must be the final recipient — the beneficial owner rather than an intermediary, agent or nominee holder. Where the agent pays the tax from its own funds without withholding, the treaty does not apply. The list of states with preferential taxation was approved by Order of the Minister of Finance No. 492 of 12 September 2025, applies from 1 January 2026 and covers 56 states and territories, including Hong Kong and Macau.

Sources

●      Tax Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025 — Division 15 on the taxation of non-residents: structure and constituent articles

●      Tax Code — article 679 on Kazakhstan-source income of a non-resident, in full

●      Tax Code — article 682 on withholding tax rates, in full

●      Tax Code — chapter 72 in full: articles 683–687 on computation, remittance and reporting

●      Tax Code — article 698 on the conditions and procedure for applying a treaty

●      Tax Code — article 702 on the requirements for the residency document

●      Tax Code — article 705 on a tax agent applying a treaty on its own initiative

●      Tax Code — article 706 on applying a treaty to dividends, interest and royalties: the conditions and the definition of the final recipient

●      Tax Code — article 707 on dividends on shares underlying depositary receipts

●      State Revenue Committee — the criteria for classifying a state as one with preferential taxation

●      Zakon.kz — Order of the Minister of Finance No. 492 of 12 September 2025: the list of 56 states with preferential taxation, in force from 1 January 2026

●      Tax Code — official text, Adilet legal information system

●      State Revenue Committee of the Ministry of Finance — guidance of 15 May 2026 on the taxation of non-residents' income

Levels of verification behind this briefing

Sources are separated by reliability on purpose.

●      Verified in the text of the Code: the list of Kazakhstan-source income and the place-irrelevant service rule (article 679); the regime for persons in states with preferential taxation; every rate, including the progressive dividend scale and the 10 per cent rate on loan interest (article 682); the computation and withholding rules, the royalty rule and the mixed-contract rule (article 683); remittance deadlines (article 684) and filing deadlines (article 685); the conditions for treaty relief and the bar where the agent bears the tax (article 698); the requirements for the residency document and the periods it covers (article 702); and the self-application procedure with its certificate deadlines (article 705).

●      Verified from official guidance: the State Revenue Committee's position on applying chapter 72 and article 683 to non-residents without a permanent establishment.

●      Additionally verified in this pass: article 706, with its four conditions for treaty relief on dividends, interest and royalties, the definition of the final recipient, the rules on payment through an intermediary and the refund mechanism operated by the agent; article 707 on dividends underlying depositary receipts; the reference and composition of the list of states with preferential taxation under Order No. 492; and the classification criteria in article 20 of the Code.

●      Outside the scope of verification: the texts of articles 680 and 681 on exclusions were not read — they are named here but not analysed, and should be consulted separately before application. The full list of 56 states is not reproduced line by line: the reference, the criteria and specific confirmed entries are given instead. The refund procedure through the tax authority (articles 699–701) is outlined only in outline. Adilet blocks automated access, so the Code was read through a legal database reproducing it verbatim, with the official source cited separately.

Related UPPERSETUP reading

●      Kazakhstan's Tax System 2026: the New Tax Code, CIT, VAT, PIT and AIFC Incentives

●      Controlled Foreign Company Rules in Kazakhstan in 2026

●      Currency Control in Kazakhstan 2026: Contract Registration Numbers and Repatriation

●      Kazakhstan + UAE: the Dual Structure in 2026

Disclaimer

This material is provided for information only and does not constitute legal, tax, financial, investment or consulting advice. Professional advice should be obtained on the specific facts, jurisdiction, entity status and current regulatory requirements before any decision is taken. Information is current as at August 2026.