Kazakhstan: Updated list of countries not treated as CFCs
Order No. 121 provides updated list applicable for 2026 and 2027.
The Ministry of Finance released Order No. 121 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 includes Lithuania, bringing the total number of countries on the list to 41.
The order becomes effective March 21, 2026, and applies to legal relations arising from January 1, 2026, through December 31, 2027.
Read a March 2026 report prepared by the KPMG member firm in Kazakhstan