Dear readers,
The Ministry of Finance introduced amendments1 to the list of tax treaty countries where the nominal income tax rate exceeds 75 percent of the corporate income tax rate in Kazakhstan. Companies registered in countries on the list are not treated as controlled foreign companies (CFCs).
The updated list:
- Excludes Ireland, Tajikistan, and Turkmenistan;
- Limits the Swiss cantons to Aargau, Bern, Ticino, and Zurich, removing Basel-Land, Solothurn, and Jura;
- Reorganizes the order of countries.
The changes took effect upon signing on 22 May 2025.
1 Order No. 247 of the Minister of Finance of Kazakhstan On Amendments to Order No. 680 of the Deputy Prime Minister 鈥� Minister of Finance of Kazakhstan On the Approval of the List of Countries with Effective International Agreements on Avoidance of Double Taxation and Prevention of Tax Evasion, Where the Nominal Corporate Income Tax Rate Exceeds 75 Percent of the Income Tax Rate in Kazakhstan, dated 22 May 2025