↳ ASTANA - KAZAKHSTAN
Where Eurasia meets English common law.
Establishing An Astana International Financial Centre Company (AIFC)
The Republic of Kazakhstan is the largest economy in Central Asia, offering political continuity, a strategic position on the Middle Corridor between China, Europe, the Caspian region and the Middle East, and direct access to the markets of the Eurasian Economic Union.
The Astana International Financial Centre (AIFC) is a special financial jurisdiction established by the Constitutional Statute of 7 December 2015. It operates under its own legal framework based on the principles of English law, with an independent regulator, an independent court and an international arbitration centre, and offers tax incentives guaranteed until 1 January 2066.
As of the current Kazakhstan tax regime (new Tax Code in force from 1 January 2026):
Standard Corporate Income Tax: 20%
0% Corporate Income Tax may apply to AIFC Participants on income from qualifying financial and ancillary services until 1 January 2066 (subject to conditions and substance requirements)
Withholding tax on dividends paid to non-residents is 15%, reduced to 5% for shareholders holding at least 25% (up to 230,000 MCI of dividends), and may be reduced further under a Double Tax Treaty.
1. Advantages
- 0% Corporate Income Tax on qualifying AIFC financial and ancillary services income until 2066
- 0% VAT on qualifying AIFC financial services
- 0% Individual Income Tax for foreign employees of AIFC Participants (until 2066)
- 100% Foreign Ownership
- English Common Law Framework, AIFC Court and International Arbitration Centre
- Fully Online Registration (from USD 500 for a Private Company)
- 55 Double Tax Treaties
- Access to Kazakhstan and Eurasian Economic Union Markets
2. Utilization
- Holding & Investment Structures
- Regional Headquarters for Central Asia
- Asset & Fund Management
- Banking, Insurance & Islamic Finance
- FinTech, Payment Services & E-Money
- Digital Asset Businesses
- Legal, Audit, Accounting & Consulting Firms
- Special Purpose Companies for Structured Finance
3. Why the AIFC?
The AIFC combines a common law environment familiar to international investors with a location inside one of the fastest-growing economies of the region. AIFC Participants may benefit from 0% corporate income tax on qualifying income, provided they carry out licensed or recognised activities in full compliance with AFSA rules and meet the Substantial Presence requirements. An independent regulator (AFSA), an independent court and a treaty network covering Europe, Asia, the Gulf and North America make the AIFC a credible platform for regional and international structuring.
4. Corporate Requirements
Common entity types:
- Private Company (Ltd) – one or more shareholders, shares not publicly traded
- Public Company – may offer shares to the public and list on the AIX
- Limited Liability Partnership / Limited Partnership / General Partnership
- Special Purpose Company (SPC) – for structured and Islamic finance transactions
- Recognised Company – branch of a foreign or Kazakhstan company
Key Features:
- 100% foreign ownership
- Minimum one shareholder (individual or corporate)
- Online incorporation via the AIFC Digital Resident Portal
- Registration fee: USD 500 online / USD 1,500 paper application (Private Company)
- Financial services require an AFSA licence; ancillary services require separate AFSA authorisation
- Physical office in the AIFC required to apply tax exemptions (Substantial Presence Rules)
Companies outside the AIFC are usually formed as a Limited Liability Partnership (LLP) or Joint Stock Company (JSC) under Kazakhstan civil law.
5. Other Requirements
VAT:
- Standard VAT rate: 16% (from 1 January 2026)
- VAT registration threshold: 10,000 MCI of annual turnover
Qualifying financial services provided by AIFC Participants are exempt from VAT.
Substantial Presence Rules apply to AIFC Participants claiming tax exemptions (real office in the AIFC, local management and staff, adequate operating expenditure).
AIFC Participants benefit from a liberalised currency regime for transactions within the AIFC.
6. Compliance & Filing
- Annual return and financial statements filed with the AIFC Registrar of Companies
- Kazakhstan tax registration and annual corporate income tax return (generally due by 31 March)
- VAT filings (if registered)
- Regulatory reporting to AFSA (licensed firms)
- AML/CFT compliance and beneficial ownership records
- Evidence of substantial presence (where tax exemptions are claimed)
AIFC Participants remain Kazakhstan taxpayers and must document eligibility for each exemption they apply.
7. Double Tax Treaty Network
Kazakhstan maintains 55 Double Tax Treaties in force, including with:
- United Kingdom
- United States
- Germany
- France
- Switzerland
- Netherlands
- United Arab Emirates
- China
- Singapore
Treaty access depends on tax residency and beneficial ownership. The OECD Multilateral Instrument (MLI), including the Principal Purpose Test, applies.
8. Type of Legal System
Civil Law system (Romano-Germanic tradition). The AIFC operates a separate legal regime based on the principles and precedents of English law, with English as the working language, the AIFC Court and the International Arbitration Centre (IAC).
9. General
The leading financial centre of Central Asia, combining a common law framework, long-term tax incentives and a gateway to the Eurasian market.
10. The Choice of an AIFC Company is a Choice of Legal Certainty & Regional Reach
The AIFC offers a predictable common law environment, potential 0% corporate taxation on qualifying income until 2066, and strategic positioning at the crossroads of Europe, Asia and the Middle East.