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Kazakhstan: New CFC forms; new whitelist of countries not considered to have preferential tax regimes

Effective January 1, 2026

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December 4, 2025

Order No. 536 (published on September 30, 2025) introduced new forms related to taxpayers’ participation in controlled foreign corporations (CFCs) effective January 1, 2026, including:

  • Application for declaring CFC shareholdings
  • Notification for revocation due to legislative breaches
  • Decision recognizing direct or indirect ownership or control if not rebutted

In addition, the Ministry of Finance on October 6, 2025, issued Order No. 579, approving a new whitelist of 40 jurisdictions not considered to have preferential tax regimes. All listed countries have effective tax treaties with Kazakhstan and maintain a corporate income tax rate exceeding 75% of Kazakhstan’s rate. The whitelist excludes Hong Kong and Macao and will apply from January 1, 2026, through December 31, 2027.


For more information, contact a KPMG tax professional in Kazakhstan:

Assiya Atekeeva | aatekeeva@kpmg.kz

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