Report on the 2025 results concerning the taxation of non-residents
26.01.2026 10:00:44 175
One of the priority areas for the state revenue authorities of East Kazakhstan region is monitoring the timely and comprehensive fulfillment of tax obligations related to corporate income tax (CIT) withheld at the source from non-resident income.
According to the Paragraph 1 of Article 679 of the newly revised Tax Code of the Republic of Kazakhstan, 39 types of non-resident income are classified as being from sources within the Republic of Kazakhstan. The most common categories include income from the sale of goods and services within the territory of Kazakhstan, the performance of work, and the provision of services—including consulting, management, financial, engineering, marketing, and auditing. This also encompasses income in the form of dividends, interest, remuneration, royalties, insurance premiums, international transportation, and increase in the value of property.
Non-resident taxation is administered through cameral audit of tax reporting form 101.04, ‘Calculation of corporate income tax withheld at the source of payment from non-resident income,’ utilizing data provided by the National Bank of the Republic of Kazakhstan."
Cameral control is carried out in the following areas:
accuracy of the calculation and withholding CIT at the source of payment, verified against National Bank of the Republic of Kazakhstan data on currency transactions and tax reporting form 101.04;
legality of applying tax exemptions and reduced rates under international double taxation treaties;
identification of instances involving the unjustified application of full withholding tax exemptions on the income of non-resident legal entities;
identification of violations and non-compliance in calculating value added tax for non-residents.
Identified violations result in an additional financial burden for taxpayers in the form of penalties, which may adversely affect their financial and economic activities. Consequently, taxpayers are advised to strictly comply with tax legislation requirements when calculating and paying CIT at the source of payment.
State revenue authorities continuously conduct activities aimed at identifying and recovering additional tax reserves within the non-resident taxation sector.

Source : https://www.gov.kz/memleket/entities/kgd-vko/press/news/details/1147499?lang=kk