
The Order of the Minister of Finance of the Republic of Kazakhstan "On approval of the Rules for Determining income from Intellectual Property and the provision of services in the field of informatization, to which a reduction in the amount of calculated corporate income tax by 100 percent is applied" was developed in accordance with paragraph 4-3 of Article 293 and paragraph 4 of Article 709 of the Code of the Republic of Kazakhstan "On Taxes and other mandatory payments to the Budget" in order to implement the OECD Standard 5 BEPS "Countering Harmful Tax Practices", which is one of the mandatory standards for application.
This standard provides for the provision of corporate income tax benefits only in terms of activities in Kazakhstan and when expenses are justified in accordance with the requirements of the economic content and the nexus approach.
According to this standard, it is necessary to limit the use of tax benefits for CPN for participants of the Astana Technopolis FEZ, the Park of Innovative Technologies, the Astana Hub International Technology Park, as well as AIFC operating in the field of IT and architecture, in case of non-compliance with the requirements of the economic content and the nexus approach.
The purpose of the adoption of this order is to determine the income from intellectual property objects and the provision of services in the field of informatization, to which a reduction in the amount of calculated corporate income tax by 100 percent is applied, by participants of the Astana Hub International Technology Park and organizations operating in the territories of special economic zones.
The order was adopted by the Ministry of Finance of the Republic of Kazakhstan on 15.12.2022 No. 1287, registered on 19.12.2022 in the Register of State Registration of Regulatory Legal Acts under No. 31144.