Kazakhstan: New CFC forms; new whitelist of countries not considered to have preferential tax regimes
Effective January 1, 2026
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