Kazakhstan’s New Tax Code - Withholding Tax Changes for Non-Resident Payments
Kazakhstan’s New Tax Code - Withholding Tax Changes for Non-Resident Payments
This update provides a neutral summary of key changes in taxation of payments to non-residents (withholding tax at source) that may interest our corporate clients. While Unicase does not provide tax advisory services, we aim to keep you informed of important legal developments. The changes outlined below are for general information only and not a substitute for professional tax advice.
New Tax code of the Republic of Kazakhstan was adopted on July 18 2025, which will come into effect on 1st of January 2026. [1]
Reduced Withholding Tax on Interest from 2026
A key upcoming change in Kazakhstan’s tax regime is the reduction of the withholding tax (WHT) rate on interest payments made by local companies to foreign lenders. Currently, in the absence of a double tax treaty, such interest payments are subject to a 15% WHT. Starting from 2026, this rate will be lowered to 10% for all non-resident creditors, regardless of treaty status[2]. The reduced rate will apply to interest on both loans and debt securities issued by Kazakhstani borrowers. Since 10% aligns with the WHT rate found in most of Kazakhstan’s double tax treaties, the need to rely on treaty benefits for interest payments will largely disappear - the domestic law will provide the same rate by default.
Reduced Dividend Withholding Tax for Qualified Shareholders
Also, Kazakhstan offers a reduced withholding tax (WHT) rate on dividends paid to nonresidents who directly or indirectly own at least 25% of the capital of the dividend-paying resident company[3].
The applicable tax rates are as follows:
5% WHT on dividend income up to the amount equivalent to 230,000 times the monthly calculation index (MCI - is an annually adjusted value used in Kazakhstan for tax and social payment purposes) which is approximately USD 1.7 million as of September 2025[4];
For dividend income exceeding that threshold, the tax is calculated as: 5% of 230,000 × MCI plus 15% on the excess amount[5].
This preferential rate is intended to encourage long-term equity investment and shareholder stability in Kazakhstani companies.
Please also note that 20% Withholding Tax Applies to Payments to Tax Haven Jurisdictions. If the income recipient is located in a jurisdiction with a preferential (low-tax) regime, commonly referred to as a "tax haven", the withholding tax (WHT) rate remains at 20%, regardless of any reduced rates available under domestic law or double tax treaties.
Kazakhstan maintains an official list of such jurisdictions, as approved by the Order of the Minister of Finance of the Republic of Kazakhstan No. 142 dated February 8, 2018. The list currently includes approximately 57 jurisdictions, covering not only traditional offshore territories, but also certain regions of mainland countries such as: Macau and Hong Kong (China), British Overseas Territories, Certain U.S. jurisdictions, Kingdom of the Netherlands (limited to the territory of Aruba and the dependent territories of the Netherlands Antilles) and others.
It is important for companies making cross-border payments to verify whether the recipient's jurisdiction is included on this list, as it directly affects the applicable tax rate.
The rates specified in this letter do not apply to a non-resident carrying out activities in the Republic of Kazakhstan through a permanent establishment.