Kazakhstan has approved a list of 41 jurisdictions eligible for double taxation treaty benefits, limited to countries with sufficiently high corporate tax rates and existing agreements, with the rules applying retroactively for 2026–2027.
Kazakhstan’s Minister of Finance has approved a comprehensive list of countries whose businesses qualify for double taxation treaty benefits based on their corporate tax rates.
The approved countries must maintain a nominal corporate income tax rate that exceeds Kazakhstan’s corporate income tax rate by at least 75%. Additionally, each country must have an active international agreement with Kazakhstan addressing double taxation avoidance and tax evasion prevention.
The list encompasses 41 jurisdictions, including major economies such as the US, China (excluding Macau and Hong Kong special administrative regions), Japan, Germany, the UK, and the Russian Federation. European nations feature prominently, with France, Italy, Spain, and the Nordic countries all included. Notably, Switzerland receives partial approval limited to four specific cantons: Aargau, Bern, Ticino, and Zurich, rather than blanket coverage for the entire confederation.
The list is used in relation to Kazakhstan’s controlled foreign company (CFC) rules, which include an exception from the rules for non-resident legal entities and other organisations registered, incorporated, or otherwise established in a country meeting the conditions for inclusion in the list.
Complete list of approved jurisdictions
- Austria
- United States of America
- Armenia
- Azerbaijan
- Belarus
- Belgium
- Vietnam
- Germany
- Japan
- Italy
- Iran
- Spain
- Canada
- South Korea
- China (except for the territories of the special administrative regions of Macau and Hong Kong)
- Latvia
- Lithuania
- Luxembourg
- Malaysia
- Mongolia
- Netherlands
- Norway
- Pakistan
- Poland
- Russia
- Romania
- Saudi Arabia
- Singapore
- Slovakia
- Slovenia
- Turkey
- Ukraine
- United Kingdom
- India
- Finland
- France
- Croatia
- Czech Republic
- Sweden
- Switzerland (only in part of the following cantons: Aargau, Bern, Ticino, Zurich)
- Estonia
The order takes effect ten calendar days following its official publication and applies retroactively to legal relationships established between 1 January 2026 and 31 December 2027.
