Kazakhstan: Updated list of countries not treated as CFCs

Order No. 247 provides updated list effective May 22, 2025.

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June 10, 2025

The Ministry of Finance released Order No. 247 (effective May 22, 2025) providing an updated list of tax treaty countries with a nominal income tax rate in excess of 75% of the corporate income tax rate in Kazakhstan and thus companies registered in these countries 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

Read a June 2025 report prepared by the KPMG member firm in Kazakhstan

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