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Market focus · 4 min

Kazakhstan Company in Russia Context

Kazakhstan became a corridor into and out of Russia for a reason — an active tax treaty and SWIFT-connected banking. The question is whether a Kazakh structure genuinely helps your position, or just adds a layer the FTS will look through.

TW
TaxWell & Partners
Tax & legal advisers · reviewed for 2026 rules
4 min read
What it offers

An active 10/10/10 tax treaty with Russia, banking access to the Western system, and EAEU membership — a real bridge where direct routes have closed.

What to watch

Russian authorities apply a substance test. A Kazakh company with no real operations is treated as a conduit, and the treaty benefit falls away — substance is what makes it hold.

10%
treaty WHT on dividends/interest/royalties
16%
Kazakh VAT from 2026
20%
Kazakh corporate income tax

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.

01

Kazakhstan's position: the key advantages

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

02

Kazakh tax rates after the 2026 Tax Code

Kazakhstan's tax rates changed materially under the new Tax Code that took effect on 1 January 2026, so figures from earlier years are out of date. The headline numbers a foreign group needs to weigh are three:

Corporate income tax remains 20% for most companies, with higher rates for banks and the gambling sector.

VAT rose from 12% to 16% from 2026 — a point worth noting for anyone modelling Kazakhstan against Russia, where the standard rate is 22%. The registration threshold was also lowered, bringing more businesses into the VAT net.

Personal income tax moved from a flat 10% to a progressive 10–15% scale, with the higher rate applying above an income threshold — relevant for executive and expatriate salaries.

None of this undermines Kazakhstan's position as an active-treaty bridge, but the numbers behind a Kazakh structure are not what they were before 2026, and a comparison built on the old 12% VAT or flat 10% income tax will understate the real cost.

₽ Kazakh rates from 2026

Corporate income tax 20%, VAT 16% (raised from 12%), personal income tax 10–15% progressive. The new Tax Code applies from 1 January 2026 — pre-2026 figures are stale.

03

Russia-Kazakhstan double tax treaty

The Russia-Kazakhstan DTT (signed 1996, updated) provides the following WHT rates:

Weighing Kazakhstan as a bridge?

Pick what applies — we'll tell you if it holds up:

We want to route payments through Kazakhstan →We were told our structure lacks substance →We need banking that still connects to SWIFT →

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

04

The banking corridor

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.

05

Common structural uses

06

Trading intermediary

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.

07

Holding company

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.

08

Banking and treasury

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.

09

Substance requirements

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.

⚠ Substance, or the FTS looks through

A Kazakh company with no real operations is treated as a conduit and the treaty benefit falls away. The 10% rate holds only with genuine substance behind the structure.

10

Setting up in Kazakhstan

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.

Frequently asked questions
Does a Kazakh company reduce my Russian tax?

It can — the Russia–Kazakhstan treaty is active and offers a 10% rate on dividends, interest and royalties, against Russia's 15%/20% domestic rates. But the benefit applies only if the Kazakh entity is the genuine beneficial owner with real substance. A paper company gets treated as a conduit and the treaty rate is denied.

What are the tax rates in Kazakhstan?

Corporate income tax is 20% for most companies, VAT is 16% from 2026 (raised from 12%), and personal income tax runs on a 10–15% progressive scale from 2026. Rates changed under the new Tax Code effective 1 January 2026, so figures from before then are out of date.

Will the FTS accept a Kazakh structure?

Only if it has substance — real operations, staff and management in Kazakhstan, not just a registered address. Russian tax authorities look through structures inserted purely to capture a treaty rate. Whether yours holds depends on the facts, which is worth testing before you build it.

Related service: Company registration →
+ how we can help

This guide explains why Kazakhstan became a corridor. The real question is whether a Kazakh structure genuinely works for your flows — or whether it's substance-thin and one FTS challenge away from failing.

Corridor structure review — Whether a Kazakh entity actually solves your banking or treaty problem — with the 10/10/10 treaty and the substance test both weighed.
Substance & beneficial ownership — The Kazakh entity built to the substance the Russian authorities require, not a nameplate that collapses under scrutiny.
Payment routing — The banking corridor set up so payments actually clear, which is usually the real reason the structure exists.
Ask about a Kazakh structure →Book a 30-min call
Or read how we handle Tax & compliance →
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