Article 414. Tax offset of a controlled foreign company of the Tax Code of the Republic of Kazakhstan

    1. The individual income tax is reduced by an amount determined in one of the following ways::

    1) the amount of corporate income tax withheld from the source of payment in the Republic of Kazakhstan during the tax period from the income or taxable income of a controlled foreign company from sources in the Republic of Kazakhstan included in the financial profit of a controlled foreign company subject to taxation (taxed) in the reporting or previous tax period in the Republic of Kazakhstan in accordance with Article 399 of this The Tax Code, with the exception of the amount of corporate income tax, withheld from the source of payment in the Republic of Kazakhstan from income in the form of dividends. The provision of this subparagraph applies to the amount of corporate income tax withheld at the source of payment, calculated using a rate of less than 10 percent, and if the provisions of paragraph 2 of Article 413 of this Code are not applied by a resident.;  

    2) the value determined in the following order:

    Hb = D x (Sk - Se)/100 %, where:  

    Hb – the tax to be deducted in accordance with this subparagraph;

    E – income or taxable income received by a controlled foreign company from sources in the Republic of Kazakhstan, with the exception of income in the form of dividends;

    Sk is the corporate income tax rate withheld in the Republic of Kazakhstan from the income or taxable income of a controlled foreign company from sources in the Republic of Kazakhstan at a rate of less than 10 percent (hereinafter referred to as the corporate income tax rate);

    Se is the effective rate of foreign income tax or other foreign tax, similar to corporate income tax in the Republic of Kazakhstan, paid in a foreign country from the financial profits of a controlled foreign company, including income or taxable income from sources in the Republic of Kazakhstan, according to which the foreign income tax is calculated, attributed or subject to offset in accordance with paragraph 2 of Article 413 of this Code (hereinafter referred to as the effective foreign income tax rate).

    The provision of the first part of this subparagraph is used in cases where the provisions of paragraph 2 of Article 413 of this Code are applied by a resident and if the corporate income tax rate is higher than the effective foreign income tax rate.  

    2. The provisions of subparagraph 1) or 2) of paragraph 1 of this article shall apply if a resident individual has copies of the following documents:

    confirming the withholding and transfer by a resident to the budget of the Republic of Kazakhstan of corporate income tax at the source of payment from income or taxable income of a controlled foreign company received from sources in the Republic of Kazakhstan;

    an internal document (documents) prepared (compiled) in a foreign language (with mandatory translation into Kazakh or Russian) confirming the inclusion of income or taxable income from sources in the Republic of Kazakhstan in the financial profit of a controlled foreign company in the Republic of Kazakhstan;

    specified in the fifth part of paragraph 4 of Article 346 of this Code when applying subparagraph 2) of paragraph 1 of this Article.  

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

President    

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 414. The specifics of issuing invoices for the sale of printed publications and other mass media products of the Tax Code and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

     In the case of the sale of periodicals or other mass media products, including those posted on an Internet resource in publicly accessible telecommunication networks, an invoice is issued no later than fifteen calendar days after the date of the turnover on sale.

     The taxpayer has the right to issue an invoice earlier than the date of the turnover for the entire sales turnover, the date of which falls on the calendar year. At the same time, the invoice separately indicates the amount of sales turnover and the corresponding amount of value-added tax for each tax period included in such a calendar year.

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