KAZAKHSTAN Law and Practice Contributed by: Assel Ilyassova, Lyazzat Zhilkibagarova and Makhabbat Mukhidinkyzy, GRATA International
is generally the gross amount of Kazakhstan-source income. Depending on the nature of the income, such income may be subject to withholding tax at rates ranging from 5% to 20% under the Tax Code. These tax implications may be reduced or exempted under an applicable double tax treaty. 3.3 Passive Income Dividends, interest and royalties derived by non-resi - dents from Kazakhstan sources are generally subject to withholding tax at a rate of 15%. This rate may be reduced, typically to 10% or 5%, under an applicable double tax treaty. 3.4 Capital Gains Non-residents are generally subject to withholding tax at a rate of 15% on capital gains derived from sources in Kazakhstan. This includes, in particular, gains from the disposal of property located in Kazakhstan that is subject to state registration, securities issued by Kazakhstan residents, and participation interests in resident legal entities or consortia, as well as shares or participation interests in non-resident entities, where 50% or more of the value of such shares, interests or assets is derived from property located in Kazakhstan. 3.5 Employment Income Kazakhstan-source employment income is gener - ally subject to personal income tax at 10% on annual income up to 8,500 monthly calculation indices (MCI) and 15% on the excess. In 2026, one MCI is equal to KZT4,325. Employment income may also give rise to social tax at a general rate of 6%. Short-term assignments are not subject to a separate domestic tax regime as such, although relief may be available under an applicable double tax treaty. Remote work - ing is not specifically regulated in the Tax Code as a standalone category, and the tax consequences are therefore assessed under the general rules. 3.6 Other Income Overall, the categories of Kazakhstan-source income derived by non-residents are broadly consistent with internationally recognised source-based taxation principles and generally follow the structure of the OECD Model Tax Convention. A notable exception is Kazakhstan’s extraterritorial approach to taxing capi - tal gains derived by a non-resident from the disposal
of shares or participation interests in a non-resident entity where 50% or more of the value is derived from the property of a Kazakhstan subsoil user. 4. OECD/G20 Global Tax Reform 4.1 Pillar One – Amount B Kazakhstan has not taken steps to implement Pillar One Amount B. 4.2 Pillar One – Amount A Kazakhstan has not implemented Pillar One Amount A. 4.3 Pillar Two Kazakhstan has not implemented the global minimum tax under Pillar Two. 4.4 Specific Features or Deviations of Pillar Two Kazakhstan has not implemented the global minimum tax under Pillar Two. 4.5 Digital Services Tax Kazakhstan has not introduced a separate digital ser - vices tax or any other standalone tax specifically tar - geting digital products or streaming services. Income derived from digital assets may, depending on the circumstances, be taxed under the general corpo - rate income tax rules, but this does not amount to a separate tax on digital products as such. Instead, Kazakhstan applies a 16% VAT to certain digital ser - vices supplied by foreign companies to individuals in Kazakhstan, with foreign suppliers generally required to register for VAT once they start receiving payments from local individuals. Kazakhstan also imposes a specific digital mining fee, although this is better char - acterised as a sector-specific levy rather than a digital services tax.
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