Changes to the List of CFC Exempt Countries

The Ministry of Finance adopted a new order¹ approving the list of countries that have effective tax treaties with Kazakhstan and where the nominal corporate income tax rate exceeds 75% of Kazakhstan’s corporate income tax rate.

Companies registered in jurisdictions on the list are not treated as controlled foreign companies (point 1 of Article 332 of the Tax Code).

The updated list included the Republic of Lithuania, bringing the total number of countries on the list to 41.

The new order enters into force on 21 March 2026 and applies to legal relations arising from 1 January 2026 through 31 December 2027.

Previously, this list was approved by Order² No. 579 of the Minister of Finance dated 6 October 2025. The new order did not explicitly state that it replaced the earlier act. It was therefore likely that the previous order would be repealed or declared invalid by a separate act.

¹Order No. 121 of the Minister of Finance of the Republic of Kazakhstan On approval of the list of countries with which an international agreement regulating the avoidance of double taxation and the prevention of tax evasion entered into force, where the nominal corporate income tax rate exceeds 75% of the corporate income tax rate in the Republic of Kazakhstan, dated 24 February 2026

²Order No. 579 of the Minister of Finance of the Republic of Kazakhstan On approval of the list of countries with which an international agreement regulating the avoidance of double taxation and the prevention of tax evasion entered into force, where the nominal corporate income tax rate exceeds 75% of the corporate income tax rate in the Republic of Kazakhstan, dated 6 October 2025