Kazakhstan has updated its list of jurisdictions eligible for CFC rule exemptions, removing several countries and Swiss cantons, effective 22 May 2025.
Kazakhstan issued Order No. 247 on 22 May 2025, amending Order No. 680 of 19 June 2023. The order updates the list of jurisdictions relevant for CFC rule exemptions, used where countries have both an income tax treaty with Kazakhstan and a nominal income tax rate over 15% (i.e., >75% of Kazakhstan’s corporate income tax rate).
A controlled foreign corporation (CFC) is a company incorporated and operating in a country different from where its controlling owners reside, typically for tax-related reasons.
Order No. 247 is effective from 22 May 2025.
Removed: Ireland, Tajikistan, Turkmenistan, and the Swiss cantons of Basel-Landschaft, Jura, and Solothurn.
Updated country list
| Countries & Cantons (Switzerland: ✔ included only) |
| Armenia |
| Belgium |
| Czech Republic |
| Germany |
| Japan |
| Malaysia |
| Pakistan |
| Saudi Arabia |
| Spain |
| United Kingdom (UK) |
| Switzerland (Cantons): Aargau ✔, Bern ✔, Ticino ✔, Zurich ✔ |
