Article 669. Exemption from payment of state duty when processing documents on acquisition of citizenship of the Republic of Kazakhstan of the Tax Code of the Republic of Kazakhstan

    1. The following persons are exempt from paying the state duty::  

    1) persons who were forced to leave the territory of the Republic of Kazakhstan during periods of mass repression, forced collectivization, as a result of other inhumane political actions, and their descendants – for processing documents on the acquisition of citizenship of the Republic of Kazakhstan;

    2) kandasy – for the registration of documents on the acquisition of citizenship of the Republic of Kazakhstan.

    2. The specified exemption from payment of the state duty is granted once.  

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 669. The procedure for applying an international agreement regarding exemption from taxation of non-resident income from the provision of international transportation services through a permanent establishment of the Code on Taxes and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

     1. A non-resident has the right to apply exemption from taxation of income from the provision of international transportation services in accordance with the provisions of an international agreement, if such a non-resident is the final recipient of income and a resident of the State with which the international agreement is concluded.

     An international agreement regarding tax exemption is applied if a non-resident has a document confirming his residence as of the date of filing the corporate income tax return.

     A document confirming residency is submitted by a non-resident to the tax authority at the location of the permanent establishment when submitting a corporate income tax return.  

     2. A non-resident is obliged to keep separate records of the amounts of income from the provision of international transportation services and other income from sources in the Republic of Kazakhstan for the tax period.

     3. The amount of expenses related to the provision of international transportation services is determined by a non-resident using the direct or proportional method.

     The chosen method of determining expenses can be changed only by agreement with the tax authority, which is superior to the tax authority at the location of the permanent establishment of such a non-resident (with the exception of the authorized body), before the beginning of the tax period.

     During one tax period, more than one method of determining expenses cannot be applied.  

     4. When using the direct cost determination method, a non-resident keeps separate records of expenses related to the provision of international transportation services and other expenses.

     5. When applying the proportional method, the amount of expenses is determined as the product of the share and the total amount of expenses of a non-resident in connection with carrying out activities in the Republic of Kazakhstan for the tax period.

     The share is defined as the ratio of the amount of income from the provision of international transportation services to the total amount of income in connection with activities in the Republic of Kazakhstan for the tax period.

     6. In the absence of a document confirming the residence of a non-resident, as of the date of submission of the corporate income tax declaration, the non-resident is not entitled to apply the provisions of an international agreement.

     In this case, in the case of calculation and payment of corporate income tax to the budget, a non-resident has the right to apply the provisions of an international agreement before the expiration of the limitation period established by Article 48 of this Code, unless other deadlines are established by an international agreement, provided that an additional corporate income tax declaration and a document confirming the residence of a non-resident are submitted to the tax authority.

     The footnote. Article 669 as amended by the Law of the Republic of Kazakhstan dated 10.12.2020 No. 382-VI (effective from 01.01.2021).  

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