Kazakhstan: Updated list of countries not treated as CFCs
Order No. 247 provides updated list effective May 22, 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