Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026.

Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and taxation of Controlled Foreign Companies (CFCs). The order was registered with the Ministry of Justice of the Republic of Kazakhstan on 26 September 2025 under No. 36945.

The primary purpose of the order is the “Approval of forms for decisions of state revenue bodies and applications regarding participation (control) in a controlled foreign company”. It is issued in accordance with Articles 49, 83, 113, and 336 of the Tax Code of the Republic of Kazakhstan.

Notification on the elimination of tax violations (Appendix 1) details the nature of any breach, referencing the specific CFC or its permanent establishment. Resident taxpayers are required to submit a declaration reflecting the tax liability in accordance with Article 335 of the Tax Code. Generally, taxpayers must eliminate violations within 30 working days from the day following delivery of the notification.

Application for participation (control) in a CFC (Appendix 2) allows resident taxpayers to report their involvement in a CFC. This includes ownership or control of 25% or more of participation or voting shares, whether direct, indirect, or constructive. The explanatory notes specify filing types—initial, routine, corrected, or liquidation—and provide guidance on reporting details such as the CFC’s type (e.g., non-resident legal entity, trust, partnership), registration numbers, and dates of financial reporting and audits.

A decision on recognising a resident taxpayer’s ownership or control in a CFC (Appendix 3) constitutes the official decision by the state revenue body after reviewing the taxpayer’s application and supporting documents. Taxpayers have the right to appeal this decision to the authorised body within 15 working days of receipt.

The order will come into force on 1 January 2026 and is subject to official publication.