For intangible services

The costs of intangible services purchased from a non–resident – an interconnected party of management, consulting, consulting, etc. are not deductible for CIT only if the non-resident - an interconnected party is registered in a state with preferential taxation. This condition also applies to expenses in order to reduce taxable income (introducedon  anuary 1,2023).

           On taxation of microfinance organizations

           For the purposes of calculating the CIT, a microfinance organization does not recognize income from reducing the size of provisions (reserves) created in the event of a decrease in the amount of the claim against the debtor in connection with the forgiveness of bad debts on a microcredit and remuneration for it within the maximum amount (coefficient 0.2) (introduced from January 1, 2024).

          On taxation of government-issued securities

          The reduction of taxable income for the purposes of calculating CIT is not made on income received by second-tier banks on state-issued securities issued by the National Bank of the Republic of Kazakhstan. The exemption for non-resident income in the form of remuneration for state-issued securities (introduced from March 1, 2024) is also excluded.

         The right to reduce taxable income by the amount of income in the form of remuneration for state-issued securities, as well as income from value gains from the sale of state-issued securities reduced by losses from the sale of these securities (effective from January 1, 2030), is excluded.

          On taxation of dividends for resident legal entities

          The provisions of the Tax Code, previously introduced on January 1, 2023, which provided for:

          - non-application of adjustments to the total annual income on KPN in terms of dividends on securities placed on the KASE and AIFC exchanges, if active trading on the exchange was not carried out during the tax period (criteria are determined by the Government of the Republic of Kazakhstan);
         - taxation of CIT in the form of income taxed at the source of payment of dividends on the above-mentioned securities if active trading on the stock exchange was not carried out during the tax period.

             On a temporary balancing board

             The provisions on the temporary balancing fee, in accordance with the legislation of the Republic of Kazakhstan on railway transport, which were in force until January 1, 2024, have been extended and are valid indefinitely. These provisions of the Tax Code provide for:

          - deduction for expenses incurred by the National Infrastructure Operator in connection with the provision of services of the mainline railway network for the carriage of passengers by rail to a railway carrier free of charge, including the application of a temporary reduction factor of 0 to the tariff for regulated services of the mainline railway network for the carriage of passengers;

        - the right for the cargo carrier to deduct expenses for the paid temporary balancing fee (within the established size) to the operator of locomotive traction in passenger traffic;
         - recognition by the operator of locomotive traction in passenger traffic as a turnover for the implementation of obtaining a temporary balancing fee;
        - non-recognition of sales turnover, provision by the National Infrastructure Operator of services of the mainline railway network for the carriage of passengers by rail to a railway carrier free of charge, including with the application of a temporary reduction factor of 0 to the tariff for regulated services of the mainline railway network for the carriage of passengers;
         - the right to offset the amount of VAT on goods, works, services used or to be used by the National Infrastructure Operator to provide a railway carrier free of charge, including with the application of a temporary reduction factor of 0 to the tariff for regulated services of the mainline railway network when transporting passengers.

           On the taxation of VAT on cryptocurrencies

           VAT exemption is provided for the sale of cryptocurrencies (introduced from January 1, 2024).