Kazakhstan as a bridging jurisdiction for Russia-linked operations. Active Russia-Kazakhstan DTT (10/10/10%), SWIFT-connected banking, EAEU customs…
Kazakhstan has emerged as one of the most important business corridors for Russia-linked trade and investment since 2022. Kazakh companies are not on Russia's unfriendly list, the Russia-Kazakhstan double tax treaty provides competitive withholding tax rates, and Kazakh banks maintain SWIFT connectivity that Russian banks have lost. For companies seeking a bridging or holding jurisdiction between Russia and the rest of the world, Kazakhstan deserves serious consideration.
Not on Russia's unfriendly list — no Government Commission approval, no mandatory discount, no Type C dividend accounts
Active Russia-Kazakhstan DTT — 10% WHT on dividends, 10% on interest, 10% on royalties
SWIFT-connected banking — Kazakh banks (Kaspi, Halyk, Bank CenterCredit) maintain full SWIFT connectivity including USD and EUR transfers
EAEU membership — no customs duties on goods moving between Russia and Kazakhstan, simplified regulatory framework
Russian language — business documentation in Russian is standard, no translation barrier
Geographic proximity — direct border, efficient logistics for goods
The Russia-Kazakhstan DTT (signed 1996, updated) provides the following WHT rates:
Dividends: 10% — competitive with China, UAE and Turkey
Interest: 10% — higher than the 0% available under the Russia-China treaty but significantly better than 20% domestic
Royalties: 10%
Capital gains: generally taxable only in the country of residence of the seller — meaning a Kazakh company selling shares in a Russian LLC is taxed in Kazakhstan, not Russia
The most practical advantage of Kazakh companies for Russia-linked operations is banking. While Russian banks are largely excluded from SWIFT and cannot process USD or EUR international transfers, Kazakh banks can:
Receive and send USD, EUR and other major currencies via SWIFT
Process transfers to and from Russian counterparties via SPFS (Russian interbank system) or correspondent arrangements
Hold foreign currency accounts for Russian-connected businesses
Issue payment cards accepted internationally
This creates a practical corridor: a Kazakh company receives payment in USD/EUR from a non-Russian counterparty, transfers funds in rubles or via internal EAEU arrangements to Russia. This corridor is used extensively by Chinese, European and other companies maintaining Russia-linked trade.
A Kazakh LLC acts as the trading entity for Russia-linked goods flows — buying from international suppliers in USD/EUR, selling to Russian buyers in rubles. The Kazakh entity handles the international banking while the Russian entity handles domestic distribution. Goods can move across the Russia-Kazakhstan border without customs duties within the EAEU framework.
A Kazakh holding company owns the Russian LLC. Dividends from Russia to Kazakhstan: 10% WHT. Dividends from Kazakhstan onwards (to a Chinese, UAE or European parent): subject to Kazakhstan's own WHT rules and applicable treaties. Kazakhstan has an extensive treaty network and a participation exemption regime for certain dividend flows.
A Kazakh entity holds the group's banking relationships — maintaining foreign currency accounts, processing international payments, managing FX. The Russian subsidiary settles intercompany accounts with the Kazakh entity in rubles via domestic transfers.
Both Russia's domestic anti-avoidance rules and the Russia-Kazakhstan DTT beneficial ownership requirements mean that a Kazakh entity used purely as a conduit — with no real management, employees or operations in Kazakhstan — risks treaty denial. Kazakhstan has also introduced its own substance rules in recent years. A credible Kazakh structure requires: a locally managed office, Kazakh-resident director, genuine commercial activity and separately maintained accounting records.
Kazakhstan LLC (ТОО — Товарищество с ограниченной ответственностью) registration: typically 5–7 working days. Minimum charter capital: KZT 100 (approximately USD 0.20). Bank account: 3–10 business days at a major Kazakh bank. The setup process is fast and inexpensive — the main investment is in building genuine substance.
Related service: Company registration →Practical support for international business in Russia.