Key Amendments to the Tax Code of the Republic of Kazakhstan Effective from January 1, 2026, Concerning the Taxation of Non-Residents
16.07.2026 05:51:36 304
Effective January 1, 2026, the new Tax Code of the Republic of Kazakhstan (Law of the Republic of Kazakhstan No. 214-VIII dated July 18, 2025) entered into force, comprehensively reforming the country's tax system. The new legislation introduces significant changes across various areas of taxation, including the taxation of non-residents.
New Withholding Tax Rates on Non-Residents' Income. Beginning in 2026, new withholding tax rates apply to certain types of income derived by non-residents. In addition, a progressive personal income tax (PIT) scale has been introduced for specific categories of income.
Pursuant to Article 682 of the new Tax Code, dividends paid to an individual who directly or indirectly owns at least 25 percent of the capital of a resident legal entity are subject to the following tax rates: 5% on the portion of dividends not exceeding 230,000 Monthly Calculation Indices (MCI); 15% on the portion exceeding this threshold.
A 10% tax rate applies to: interest on loans and credits; income from debt securities; and winnings from gambling and betting activities.
Introduction of a Progressive Personal Income Tax Scale
Under Articles 692 and 693 of the Tax Code, a progressive PIT scale has been introduced for: employment income of non-resident employees; and income of foreign citizens and stateless persons seconded by a non-resident legal entity that is not registered as a taxpayer in the Republic of Kazakhstan.
The applicable rates are: 10% on income up to 8,500 MCI; 15% on the portion exceeding 8,500 MCI.
Accordingly, the progressive tax rates apply exclusively to the employment income of the above categories of non-resident individuals. Income Taxed at Existing Rates Certain categories of non-resident income continue to be taxed under the existing rules.
Income received by non-resident individuals under civil law contracts (service agreements), as well as other non-employment income of non-residents, remains subject to a 20% withholding tax without the application of tax deductions.
The following types of income continue to be taxed at 15%: dividends (except where the new progressive rules apply); capital gains; interest income; and royalties.
Abolition of Certain Dividend Tax Exemptions. Under the previous version of the Tax Code, Article 646 provided tax relief for dividend income where specific conditions were met, including the requirement that shares or participating interests had been held for more than three years.
Effective January 1, 2026, these tax incentives have been abolished. Consequently, the preferential tax treatment previously available for qualifying dividend income is no longer applicable.
New Taxation Rules for Non-Resident Labour Immigrants
The 2026 Tax Code also introduces significant changes to the taxation of income earned by non-resident labour immigrants.
The taxable income of a non-resident labour immigrant consists of:
- a minimum taxable income equal to 40 Monthly Calculation Indices (MCI) for each month during which work is performed or services are rendered; and
- the amount by which the income payable under the employment contract exceeds the minimum taxable income for the relevant period, where such excess exists.
The taxable excess is calculated as follows:
- income received for work performed or services rendered during each month of the relevant period;
- less the minimum taxable income for the same period;
- less an additional deduction equal to 14 Monthly Calculation Indices (MCI) for each month during which work is performed or services are rendered.
Payment of Personal Income Tax. Personal income tax calculated on the minimum taxable income must be paid before obtaining or extending the labour immigrant's permit, at the place of residence (stay) of the non-resident labour immigrant.
Personal income tax calculated on the taxable excess must be paid no later than ten calendar days after the deadline for filing the Declaration of Income and Property for the relevant tax period.
Filing of the Tax Return. A non-resident labour immigrant is required to submit the Declaration of Income and Property to the tax authority at the place of residence (stay) no later than July 1 of the year following the reporting tax period.

Source : https://www.gov.kz/memleket/entities/kgd-vko/press/news/details/1258476?lang=ru