The Tax Code of the Republic of Kazakhstan defines a list of income of a non-resident that is recognized as income from sources in the Republic of Kazakhstan.

Thus, in accordance with the Tax Code, income of a non-resident from sources in the Republic of Kazakhstan includes, among other things, income derived from the performance of works and the provision of services within the territory of the Republic of Kazakhstan.

Income from sources in the Republic of Kazakhstan of a non-resident legal entity whose activities do not result in the formation of a permanent establishment in the Republic of Kazakhstan (hereinafter, for the purposes of this chapter, referred to as a "non-resident") is subject to corporate income tax at source without deductions.

At the same time, income of a non-resident from the provision of freight forwarding (transport and forwarding) services is subject to taxation at the source of payment at a rate of 20 percent.

If a contract with a non-resident contains provisions for the performance or rendering of various types of work or services within and outside the Republic of Kazakhstan, the procedure for calculating and withholding income tax at source established by this article shall apply to each type of work or service separately. Each stage of work performed or services rendered by a non-resident within a single production and technological cycle shall be considered a separate type of work or service for the purposes of calculating and withholding income tax at source from the non-resident's income.

In this case the total amount of the non-resident's income under the above-mentioned contract must be reasonably distributed between income received from the performance of work or the provision of services within and outside the Republic of Kazakhstan.

For the purposes of applying the provisions of this paragraph, a non-resident shall be required to provide the recipient of services with copies of accounting documentation executed in accordance with the legislation of the Republic of Kazakhstan and/or a foreign state, confirming the distribution of the total amount of the non-resident's income into income received from the performance of work and the provision of services in the Republic of Kazakhstan and income received from the performance of work and provision of services outside its territory.

 In the absence of such distribution or in the event of an unjustified distribution of the non-resident's income, resulting in an understatement of the amount of the non-resident's income taxable in the Republic of Kazakhstan in accordance with the provisions of this article, the total amount of the non-resident's income received under the above-mentioned contract from the performance of work and the provision of services both in the Republic of Kazakhstan and abroad shall be subject to taxation.  

Source : https://www.gov.kz/memleket/entities/kgd/press/news/details/1170342?lang=kk