Article 241. Income on doubtful obligations of the Tax Code of the Republic of Kazakhstan

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 1. Obligations arising from purchased goods, works, services, as well as accrued employee incomes that are not satisfied during the three-year period are considered doubtful.

 Income on doubtful obligations under loans received (loans, micro-loans) does not include the amount of the loan received (loan, micro-loan).

 Doubtful liabilities are subject to inclusion in the taxpayer's total annual income, except for value-added tax, which is subject to exclusion from the offset.

 For the purposes of applying this article, the employee's income is determined in accordance with Article 426 of this Code.

 2. Income from doubtful liabilities is recognized in the tax period in which the three-year period has expired, calculated as:

 1) for doubtful obligations arising under loan (loan, micro–loan) agreements - from the day following the due date of remuneration in accordance with the terms of the loan (loan, micro-loan) agreement;

 2) for doubtful obligations arising under lease agreements – from the day following the due date of the lease payment in accordance with the terms of the lease agreement;

 3) for doubtful obligations arising from accrued employee income – from the date of accrual of employee income;

 4) for doubtful obligations not specified in subitems 1) – 3) of this paragraph:

 from the day following the expiration date of the obligation for purchased goods, works, and services, the deadline for which has been determined;

 from the date of transfer of goods, performance of works, provision of services under an obligation for purchased goods, works, and services, the term of which has not been determined.

 3. The provisions of this article do not apply to remuneration on loans that are not deductible, taking into account the provisions of paragraph 3 of Article 263 of this Code.

The Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII SAM.

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Republic of Kazakhstan

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From January 1, 2026, to invalidate the Code of the Republic of Kazakhstan dated December 25, 2017 "On Taxes and Other Mandatory payments to the Budget" (Tax Code) in connection with the entry into force of the Tax Code dated July 18, 2025 No. 214-VIII SAM.

Article 241. Adjustment of the total annual income of the Code on Taxes and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

1. Unless otherwise stipulated by paragraph 2 of this Article, the following shall be excluded from the total annual income of taxpayers::

1) dividends;

2) excluded by the Law of the Republic of Kazakhstan dated 10.12.2020 No. 382-VI (effective from 01.01.2020);

3) the amount of mandatory calendar, additional and extraordinary contributions from banks received by an organization that provides mandatory deposit guarantees for individuals;

4) the amount of guarantee contributions received by a Single Housing Construction Operator, within the limits of funds aimed at increasing the reserve for the settlement of warranty cases in accordance with the Law of the Republic of Kazakhstan "On Equity Participation in Housing Construction";

5) the amount of mandatory, additional and extraordinary contributions of insurance organizations received by the Insurance Benefit Guarantee Fund;

6) the amount of money received by the organization providing mandatory deposit guarantees for individuals and the Insurance Benefit Guarantee Fund in order to satisfy their claims for reimbursed deposits and made guarantee and compensation payments;

7) the amount of money received by a Single Housing Construction Operator in order to satisfy payment requirements upon completion of the construction of multi-family residential buildings in accordance with the Law of the Republic of Kazakhstan "On Equity Participation in Housing Construction";

8) investment income received in accordance with the legislation of the Republic of Kazakhstan on social protection and allocated to individual retirement accounts;

9) investment income received in accordance with the legislation of the Republic of Kazakhstan on social protection and aimed at increasing the assets of the State Social Insurance Fund;

10) investment income received in accordance with the legislation of the Republic of Kazakhstan on compulsory social health insurance and aimed at increasing the assets of the Social Health Insurance Fund;

11) investment income received:

joint-stock investment funds from investment activities in accordance with the legislation of the Republic of Kazakhstan on investment and venture funds and accounted for by the custodian of the joint-stock investment fund;

investment funds registered in accordance with the applicable law of the Astana International Financial Center and registered by the custodian or the management company of the investment fund;

11-1) income from the sale of digital assets, for which income is calculated in accordance with paragraph 1 of Article 227-1 of this Code;

12) income from assignment of debt claims received by a special financial company under a securitization transaction in accordance with the legislation of the Republic of Kazakhstan on project financing and securitization;

13) net income from the trust management of property received (to be received) by the founder of the trust management;

14) excluded by the Law of the Republic of Kazakhstan dated 06/24/2021 No. 53-VII (effective from 01.01.2022).

15) the amount of annual mandatory contributions received by the fund for guaranteeing the fulfillment of obligations under grain receipts from grain receiving enterprises;

16) the amount of money received by the fund for guaranteeing the fulfillment of obligations under grain receipts in order to satisfy the requirements for the guarantee payments made;

17) income of the state-owned Islamic special financial company received from the rental (lease) and (or) sale of immovable property specified in subparagraph 6) of paragraph 3 of Article 519 of this Code, and land plots occupied by such property;

18) the income received by the Islamic bank in the process of money management in the form of investment deposits, directed to the accounts of depositors of these investment deposits and located on them. Such income does not include the remuneration of the Islamic bank.;

19) income from assignment of the right to claim debt received by an Islamic special financial company established in accordance with the legislation of the Republic of Kazakhstan on the securities market;

20) the income of an organization providing mandatory deposit guarantees for individuals received as a result of the placement of special reserve assets, as well as in the form of penalties applied to second-tier banks for non-fulfillment or improper fulfillment of obligations under the accession agreement in accordance with the Law of the Republic of Kazakhstan "On Mandatory Guarantee of Deposits placed in Second-tier Banks of the Republic of Kazakhstan".

The provisions of this subparagraph shall apply provided that these revenues are allocated to increase the special reserve.;

21) the income of an autonomous cluster fund, defined by the legislation of the Republic of Kazakhstan on an innovation cluster, received from the budget in the form of a targeted transfer exclusively for the creation of joint ventures with multinational corporations, as well as for equity participation in foreign investment funds;

22) investment income of a Single Housing Construction Operator in accordance with the Law of the Republic of Kazakhstan "On Equity participation in housing Construction" within the limits of funds aimed at increasing the reserve for the settlement of warranty cases;

23) the income of a non-profit organization provided for in paragraph 2 of Article 289 of this Code, subject to the conditions established by Article 289 of this Code.;

24) income of the attorney (agent) of the authorized body in the field of education in the form of an awarded penalty in connection with the implementation of activities to reimburse budget expenditures, as well as for the repayment of state educational and state student loans;

RCPI's note! Subparagraph 25) is valid until 01.01.2029 in accordance with the Law of the Republic of Kazakhstan dated 26.12.2018 No. 203-VI.

25) the value of property gratuitously received by a venture fund established in accordance with the legislation of the Republic of Kazakhstan and intended for gratuitous transfer to legal entities specified in subparagraph 6) of paragraph 1 of Article 293 of this Code;

26) investment income of the Insurance Benefit Guarantee Fund in accordance with the Law of the Republic of Kazakhstan "On the Insurance Benefit Guarantee Fund" within the limits of funds aimed at increasing the damage compensation reserve and the insurance benefit guarantee reserve;

27) income generated upon termination of obligations in accordance with the civil legislation of the Republic of Kazakhstan on a loan (loan, microcredit) issued by a bank (microfinance organization), in the form of:

principal debt forgiveness;

forgiveness of arrears of remuneration, commission, penalty (penalty fee, fine);

income received by the borrower as a result of payment for such a person by a bank, an organization engaged in certain types of banking operations, as well as by a collection agency of a state fee levied on a statement of claim filed with the court.

28) was valid until 01.01.2023 in accordance with the Law of the Republic of Kazakhstan dated 11.07.2022 No. 135-VII. RCPI's note! The second part of paragraph 1 is valid until 01.01.2027 in accordance with the Law of the Republic of Kazakhstan dated 25.12.2017 No. 121-VI.

Income from carrying out activities provided for by the legislation of the Republic of Kazakhstan on banks and banking activities, included in the total annual income of such an organization and transferred to the parent bank, is excluded from the total annual income of a subsidiary of the bank that acquires doubtful and uncollectible assets of the parent bank.

RCPI's note! The third part of paragraph 1 is valid until 01.01.2027 in accordance with the Law of the Republic of Kazakhstan dated 25.12.2017 No. 121-VI.

At the same time, the allocation of income to be received to income from the types of activities provided for by the legislation of the Republic of Kazakhstan on banks and banking activities is carried out in accordance with the procedure determined by the authorized body for regulation, control and supervision of the financial market and financial organizations in coordination with the authorized body.

RCPI's note! The fourth part of paragraph 1 is valid until 01.01.2027 in accordance with the Law of the Republic of Kazakhstan dated 25.12.2017 No. 121-VI.

Income from the assignment of claims received in connection with the repurchase from an organization specializing in improving the quality of loan portfolios of second-tier banks, the sole shareholder of which is the Government of the Republic of Kazakhstan, previously assigned to such an organization the rights of claims on loans (loans), is excluded from the total annual income of the bank.

2. Dividends cannot be excluded from the total annual income.:

1) excluded by the Law of the Republic of Kazakhstan dated 10.12.2020 No. 382-VI (effective from 01.01.2020); 2) excluded by the Law of the Republic of Kazakhstan dated 11.07.2022 No. 135-VII (effective from 01.01.2023).

3) received by a permanent establishment of a non–resident legal entity in the Republic of Kazakhstan. At the same time, the provisions of this subparagraph do not apply to dividends if the conditions specified in subparagraph 3 are fulfilled) paragraph 9 of Article 645 of this Code;

4) Excluded by the Law of the Republic of Kazakhstan dated 12.12.2023 No. 45-VIII (effective from 01.01.2023).

3. When switching to a different inventory valuation method than that used by the taxpayer in the previous tax period, the taxpayer's total annual income is subject to an increase by the amount of the positive difference and a decrease by the amount of the negative difference resulting from the application of the new valuation method.

The transition to a different method of inventory assessment is made by the taxpayer from the beginning of the tax period.

The Code of the Republic of Kazakhstan dated December 25, 2017 No. 120-VI SAM.

This Code establishes the fundamental principles of taxation, regulates power relations for the establishment, introduction, amendment, cancellation, procedure for calculating and paying taxes and other mandatory payments to the budget, as well as relations related to the fulfillment of tax obligations.

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Republic of Kazakhstan

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