Kazakhstan: Taxation of controlled foreign companies (CFCs)

Kazakhstan: Taxation of controlled foreign companies

Changes to the taxation of controlled foreign companies (CFCs) or permanent establishments of CFCs were enacted in Kazakhstan.


Under these measures, the criteria for determining ownership or control over a foreign company are determined as of 31 December of the reporting period. A foreign entity is not regarded as a CFC if the entity:

  • Is registered in a tax treaty-partner country that has a nominal income tax rate of greater than 75% of the corporate tax rate in Kazakhstan (the tax authorities will approve the list of such countries on an annual basis)
  • Has an aggregate income less than an established threshold (not applicable for companies registered in “tax haven” jurisdictions)
  • Reports losses in stand-alone financial statements

The law introduces two formulas for the calculation of the CFC’s financial profit in Kazakhstan. A CFC can be exempt from taxation in Kazakhstan if certain requirements are satisfied.

For more information, contact KPMG’s Global Head of International Tax:

Rodney Lawrence | +1 (312) 665 5137 | rlawrence@kpmg.com

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