Taxation of non-resident income in the form of remuneration (CIT)
20.02.2026 09:54:27 241
Taxation of non-resident income in the form of remuneration (CIT) in the Republic of Kazakhstan
If a non—resident receives income from sources in the Republic of Kazakhstan, it is important to understand how it is taxed.
According to the Tax Code of the Republic of Kazakhstan:
Non-resident's income in the form of remuneration is recognized as income from sources in the Republic of Kazakhstan.
The term "remuneration" is used in the meaning established by art. 12 of the Tax Code.
If the activity of a non-resident does NOT lead to the formation of a permanent establishment in the Republic of Kazakhstan:
Income is subject to corporate income tax (CIT)
at the source of payment
without deductions.
Tax rates:
15% — on remuneration (except loans and debt securities)10% — for rewards:
on loans (loans)
on debt securities
Important! International treaties have priority
If an international treaty on the avoidance of double taxation has been concluded and ratified between the Republic of Kazakhstan and a non-resident country, its provisions shall apply.
The application of the norms of an international agreement by a tax agent is carried out in accordance with the procedure provided for in Article 706 of the Tax Code of the Republic of Kazakhstan.
Conclusion:
When paying remuneration to a non-resident, it is necessary to:
determine the source of income
and verify the availability of a permanent establishment
apply the bid correctly
and take into account the norms of the international agreement
If you work with foreign contractors, it is important to calculate the tax consequences in advance.
Source : https://www.gov.kz/memleket/entities/kgd-kostanay/press/news/details/1165870?lang=kk