Page 26 - CEE Tax Guide 2024

Kazakhstan VAT options in 6) motor vehicle
Kazakhstan Applicable / limits 7) crude oil, gas condensate

Distance selling No 8) alcohol-containing medical products registered
in accordance with the legislation of the Republic
Call-off stock No of Kazakhstan as medicinal products.
Mazars LLP
34, Abish Kekilbaiuly st, VAT group registration No Sellers of fuel and diesel are also liable for Excise Tax.
Business center Capital Tower Cash accounting – yearly
Almaty, Kazakhstan amount in EUR (approx.) No Personal income tax / Social security system
Phone: +7 727 355 40 00 Import VAT deferment No A resident of the Republic of Kazakhstan shall be any
E-mail: infoca@mazars.kz
Local reverse charge ü individual who stays in the country at least 183 calendar
Option for taxation days in any consecutive 12-month period ending
in the current tax period (calendar year) or, though not
letting of real estate No permanently residing in the Republic of Kazakhstan,
whose center of vital interests is within the Republic
Corporate taxes and other direct taxes sponsorship fees. Also, thin capitalization rule is applied supply of used real estate No of Kazakhstan.
to interest on related party loans. The list is not exhaustive. VAT registration 74 mKZT (approx. 151 kEUR)
In general, the concept resembles the CIT concept Depreciation expenses on fixed assets differ from IFRS threshold Income from employment is taxed at the rate of 10%
applied in developed countries worldwide. Taxable principles and are calculated on a group basis based on tax regardless of the tax residency status of an individual.
income is calculated as annual income minus expenses. book value as of the reporting date. Loss carry-forward can 3) tobacco products For other types of incomes, the rate depends on the type
It is possible to deduct expenses linked to incomes be done within the following 10 calendar years inclusively, 4) heated tobacco products and nicotine-containing of income and tax residency status of an individual.
recognized for CIT purposes, provided that such expenses the rule on the carrying forward of losses does not apply liquids for use in electronic cigarettes Social Tax and Social Contributions are paid at the expense
are properly documented. Dividends and capital gains to losses generated from the sale of securities, etc. There of an employer. Mandatory pension fund contributions
are not excluded from taxable income by default, are Controlled Foreign Company rules (CFCs). 5) gasoline (except for jet fuel), diesel fuel ethanol and mandatory social health insurance contributions are
it is necessary to analyze who is the beneficiary etc. mix petrol (gasohol), phenol, nephras, mixed light withheld from employment income by the employer.
to identify the applicable taxation regime. There are certain WHT applies to incomes paid to non-residents who are hydrocarbons, ecological fuel
limits on deductibility of expenses such as: up to 3% not registered for tax purposes in Kazakhstan. Taxable
of taxable profit for certain fees paid to companies from incomes are listed in the Tax Code. Kazakhstan has signed
offshore jurisdictions, up to 4% of taxable profit for 55 treaties on the avoidance of double taxation. The treaty
rates prevail over the Tax Code; however, any non-residents
Transfer pricing in Kazakhstan are required to have a duly issued tax residency certificate
in order to apply the treaty. The multilateral instrument
Arm's length principle ü Since 2009 (MLI) entered into force in Kazakhstan from October
Documentation liability ü Since 2009 2020; however, it is important to check the MLI accession
APA ü Since 2009 documents signed with each country as some of them have
Country-by-Country Since 2016 not signed/ratified the MLI or have done so under certain Average wage
liability ü conditions. Wage related taxes in Kazakhstan Minimum wage in private sector
Master file-local file Small and medium businesses may enjoy a special tax
(OECD BEPS 13) ü Since 2019 regime according to which the Unified Tax on income Exchange rate KZT/EUR 490 in EUR in KZT in EUR in KZT
applicable is paid. Such tax replaces CIT. 173 85,000 700 343,000
Penalty 819
VAT and other indirect taxes Total wage cost 203 117.00% 117.00%
lack of documentation ü From EUR 730 to EUR 7,300. Employer's social security and other contributions 29 17.00% 119 17.00%
The VAT concept is quite similar to the concept applied Gross salary 700
tax shortage ü From 20% up to 300% in developed countries worldwide. The VAT applicable 173 100.00% 100.00%
of tax shortage.
to turnover is in general based on the total value of sales Personal income tax 17 10.00% 70 10.00%
TP rules apply to all cross- (Output VAT). VAT payable to suppliers (input VAT) Employees' contributions 16 9.00% 63 9.00%
border transactions even is offset against from Output VAT. Input VAT cannot Net salary
if the parties are unrelated. be offset if goods, works, and services purchased are 141 81.00% 567 81.00%
The transfer pricing law defines
related parties as individuals not related to taxable turnover, a VAT-invoice is not
or legal entities whose special issued by a supplier or is issued with the violation of the
mutual relations may allow
Related parties the economic results of the legal requirements, the supplier is declared by a court
transactions to be influenced. to be an inactive entity, etc. The VAT rate for export goods
In consequence, the Kazakh is 0%, and there is a certain procedure for the refund of the
authorities can treat any related input VAT. Special VAT procedures apply to the
transaction as a transaction
between related parties based export/import of goods to/from the countries belonging
on their set of market prices. to the Eurasian Economic Union such as Russia, Belarus,
Kyrgyzstan, and Armenia.
A 10% deviation is allowed Ludmila Dyakonova
Safe harbors only for producers Excise Tax is paid by importers or sellers of Partner
of agricultural products. Phone: +7 727 355 40 00
Level of attention paid by Tax 1) all types of alcohol E-mail: ludmila.dyakonova@mazars.kz
Authority 8/10 2) alcoholic products

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