Taxation of income of a non-resident legal entity, without establishing a permanent establishment in the Republic of Kazakhstan, in the form of remuneration
06.02.2026 17:51:07 1341
The Department of State Revenue for the Mangystau region informs that a non-resident pays taxes in the Republic of Kazakhstan on income from sources in the Republic of Kazakhstan in accordance with the provisions of the Tax Code.
In accordance with the Tax Code, non-resident income in the form of remuneration is also recognized as income from sources in the Republic of Kazakhstan.
In this case, the term "remuneration" is used in accordance with the definition established by Article 12 of the Tax Code.
Income from sources in the Republic of Kazakhstan of a non-resident legal entity, whose activities do not lead to the formation of a permanent establishment in the Republic of Kazakhstan, is subject to corporate income tax at the source of payment without deductions.
At the same time, non-resident income in the form of remuneration, with the exception of remuneration on loans (loans) and debt securities, is subject to withholding tax at a rate of 15 percent. Non–resident income in the form of remuneration on loans (loans), debt securities - 10 percent.
At the same time, international treaties ratified by the Republic of Kazakhstan have priority over the Tax Code. The procedure and conditions of operation in the territory of the Republic of Kazakhstan of international treaties to which the Republic of Kazakhstan is a party are determined by the legislation of the Republic of Kazakhstan.
At the same time, the application of the provisions of an international agreement by a tax agent to non-resident income in the form of remuneration received from sources in the Republic of Kazakhstan is carried out in accordance with the procedure established by Article 706 of the Tax Code.
(unofficial translation)

Source : https://www.gov.kz/memleket/entities/kgd-mangistau/press/news/details/1158520?lang=kk