In connection with the introduction of the new Tax Code effective from 1 January 2026, the Order of the Minister of Finance of the Republic of Kazakhstan dated 5 March 2018 № 334 «On approval of the application form on participation (control) in a controlled foreign company» has been re-approved.

     At the same time, the Order was supplemented with a new form of decision on recognizing a resident taxpayer as directly or indirectly, or constructively owning participation interests, or having direct or indirect, or constructive control in a controlled foreign company.

     This form is completed by the tax authorities in cases where a resident is recognized as directly or indirectly, or constructively owning participation interests, or recognized as having direct or indirect, or constructive control in a controlled foreign company. Such a decision shall be sent to the taxpayer no later than three working days from the date of adoption of the said decision.

     Upon receipt of the above-mentioned decision and in case of agreement with the information specified in the decision, the taxpayer shall be obliged to submit an application on participation (control) in a controlled foreign company.

     In case of disagreement with the decision of the tax authority, the taxpayer shall be entitled to appeal this decision to the authorized body no later than 15 working days from the date of receipt of such decision.

Source : https://www.gov.kz/memleket/entities/kgd/press/news/details/1121582?lang=kk