Case study: a tax compliance check-up for a Chinese cross-border logistics company in Kazakhstan — taxes, filing calendar and risk checklist under the new Tax Code

Summary

As of October 12, Kazakhstan's new Tax Code has been in force for more than nine months. This report runs a compliance check-up on a hypothetical Chinese-owned cross-border logistics company, moving from background to applicable law, taxes, a filing calendar, risks and recommendations. Every provision cited was checked against the current text of the Code published on adilet.zan.kz, alongside official guidance. The company is invented for illustration and does not represent any real business.

1. The case (hypothetical)

"A Logistics" is a wholly owned Almaty subsidiary (TOO/LLP) of a Chinese company. It runs trucks on the Khorgos–Almaty route and provides import and export freight forwarding, owns a dozen tractor units, leases a warehouse and employs local drivers. A general manager and a finance manager are seconded from China. Each quarter the subsidiary pays a management fee to its Chinese parent and interest on a shareholder loan.

1. Which law applies

The governing law is the Tax Code of the Republic of Kazakhstan No. 214-VIII, in force since January 1, 2026; the 2017 Code (No. 120-VI) lapsed on the same date (Article 848), though it still governs audits and assessments for 2025 and earlier years. The only amendment in force this year, Law No. 308-VIII (from July 1), is a technical update of terms and agency names and does not touch rates. The monthly calculation index (MRP) for 2026 is KZT 4,325 (Article 7 of Budget Law No. 239-VIII).

In September the Ministry of National Economy published draft 2027 amendments; comments closed on September 25. According to Zakon.kz and Vlast.kz (September 4), the draft would widen the concept of tax agent and suspend e-invoicing for arrears unpaid for over six months. It has not been adopted and is not treated here as current law. Under Article 23(2), changes that increase the tax burden must be adopted by July 1 and can take effect no earlier than January 1 of the following year.

1. Which taxes apply

Corporate income tax (CIT): 20% standard rate (Article 357; consistent with State Revenue Committee (SRC/KGD) guidance of September 2025).

VAT: 16% standard rate (Article 503). For a carrier that also forwards freight, three separate questions arise.
Zero rate for international transport (Article 468): carriage of export and import cargo, and of transit cargo across Kazakhstan, is zero-rated if it moves under a single international transport document: a consignment note (tovarno-transportnaya nakladnaya) for road haulage, a through waybill or bill of lading for multimodal carriage. Where several carriers share a route, only the carrier that takes the goods to the Kazakh border, or brings them into Kazakhstan in its own vehicles, performs international transport. So if A Logistics merely subcontracts the domestic Khorgos–Almaty leg, that leg will usually not qualify and may attract 16% VAT. Each shipment needs its own assessment.
Freight forwarding (Articles 457, 475 and 494): carriers' services to the client under a forwarding contract are not the forwarder's turnover; its turnover is its fee. Forwarding of export, import and transit cargo, and loading, unloading and transshipment, are VAT-exempt. Exempt is not the same as zero-rated: whether input VAT can be credited, and how it is apportioned, follows the VAT chapters of the Code. The forwarder must issue invoices whether or not it is VAT-registered, splitting the amounts of VAT-registered and non-registered carriers and showing its own fee on a separate line, and must keep a tax register under Article 205.
Buying carriage from foreign carriers: the place of supply follows Article 459, and whether reverse-charge VAT applies under Article 454 must be checked service by service.

Personal income tax and social tax: wages are taxed at 10%/15% via withholding (Article 363); social tax is 6% (Article 557); social contributions are reported on the same form 200.00. A seconded employee who spends 183 days in Kazakhstan in any 12-month period becomes a Kazakh tax resident (Article 222).

Vehicle tax: charged on vehicles registered in Kazakhstan; trailers are excluded (Article 564). Trucks and special vehicles are taxed by payload, trailer excluded; above 5 tonnes the rate is 9 MRP a year at the January 1 MRP (Article 565), about KZT 38,925 per truck in 2026. Which band a tractor unit falls into depends on its registration category. Vehicles bought or sold mid-year are taxed pro rata by month (Article 566).

Property and land: buildings owned by a company bear 1.5% property tax (Articles 588–596). A Logistics leases its warehouse, so this only arises if it owns real estate. Owned land bears land tax; land leased from the state carries a land-use fee instead (Articles 617–624).

Road transit charges (Section 14 of the Code, "Fees"): a Kazakh vehicle leaving the country on an international haul pays 1 MRP per trip; a foreign vehicle entering, leaving or transiting pays 30 MRP, which mainly concerns foreign partner carriers; overweight and oversized vehicles pay by excess and distance (Article 616). If travel without a permit or over the limits is detected, the charge is due within five working days (Article 614), and charges paid are neither offset nor refunded (Article 121). Tolls on toll roads are governed outside the Tax Code and are not covered here.

Withholding tax: 20% on the management fee and 10% on loan interest paid to the parent (Article 682). A non-resident's income from international transport is subject to 5% withholding (Article 682(1)(4)); international transport means carriage between Kazakhstan and another country, not a leg wholly abroad or wholly within Kazakhstan (Article 679). Under Article 8 of the China–Kazakhstan treaty, profits from international road transport are taxable only in the carrier's country of residence, provided the Chinese carrier documents its residence under Articles 698 and 702. Treaty-exempt payments must still be reported on form 101.04.

Import VAT: trucks and parts imported from the Eurasian Economic Union (for example Russia) go through form 328.00 (Article 530); imports from China are taxed through the customs declaration.

Simplified regime: a company more than 25% owned by other legal entities cannot use the simplified declaration (Article 723), so form 910.00 is out of scope.

1. Filing and payment calendar (general regime)

Form numbers come from Ministry of Finance Order No. 695, except form 328.00. "M+2" means the second month after the quarter ends.

100.00, CIT return: by March 31 of the following year (Article 359); tax due within 10 calendar days of the filing deadline, i.e. by April 10 (Article 347).
101.02, CIT advance payment calculation: by April 20 of the current year, with a supplementary calculation possible until December 31. Advances apply to companies whose adjusted annual income for the year before last exceeded 600,000 MRP and are paid monthly by the 25th: in Q1, one twelfth of the prior-year calculation (computed by the tax authority); in Q2–Q4, one twelfth of the prior year's tax (Articles 348–350). Newly formed companies pay no advances in their first year.
300.00, VAT return: quarterly, between the 15th of the month after the quarter and the 15th of M+2 (Article 505); payment by the 25th of M+2 (Article 506). Zero-rated international transport goes on 300.01, exempt forwarding on 300.02, services bought from non-residents on 300.04.
200.00, PIT and social tax return: quarterly by the 15th of M+2, with the annual per-employee breakdown filed with the Q4 return. PIT is remitted within 25 calendar days after the month of payment, social tax by the 25th of the following month (Articles 440, 445, 560–562).
101.04, non-resident withholding calculation: by the 15th of M+2 for Q1–Q3 and by March 31 for Q4 (Articles 356 and 685); tax remitted within 25 calendar days after the month of payment (Article 684).
700.00, vehicle, land and property tax return: by March 31 of the following year; vehicle tax (700.01) where the vehicles are registered, land tax (700.02) where the land lies, property tax on 700.03; payment within 10 calendar days of the filing deadline (Articles 567, 569, 587).

Where applicable:
701.01, current property tax payments: if the company owns buildings and the tax exceeds 300 MRP, file by February 15 and pay in instalments by February 25, May 25, August 25 and November 25 (Article 596).
851.00, current land-use fee payments: for land leased from the state, by February 20 (Article 624).
328.00, application for import of goods and payment of indirect taxes: for EAEU imports, file and pay VAT by the 20th of the month after the goods are recorded (Article 530). According to a reprinted SRC notice, since February 16, 2026 it can only be filed through the new Taxpayer Office.
Road transit charges have no return; they are paid before the permit is issued.

Next deadline: Q3 2026 forms 200.00, 300.00 and 101.04 are due by November 15. That is a Sunday; check with an accountant whether it rolls over, or simply file early. Q3 VAT is payable by November 25 (Wednesday). If a return is not filed on time the system generates a nil return automatically, but where there is taxable activity a real return must replace it (Article 115).

1. Risk checklist

1. Tax residence: a foreign company effectively managed from Kazakhstan is a resident (Article 223). If the Chinese head office actually takes decisions in Kazakhstan, residence may be asserted.
2. Permanent establishment: if the parent itself sends staff to perform services in Kazakhstan for more than 183 days in any 12-month period, a PE arises (Article 228); the China treaty uses a 12-month test for construction and services. Income of an unregistered PE is taxed at source at 20% with no deductions (Article 691).
3. VAT registration: apply within five working days after passing 10,000 MRP, or before a single transaction that would exceed it (Article 101; consistent with Akmola regional tax office guidance). Companies more than 25% owned by legal entities cannot use the simplified declaration regime (Article 723); unproven zero-rated turnover is taxed at 16% (Article 503(4)).
4. Payments to China: treaty rates require a Chinese tax residence certificate meeting Article 702; payments to recipients in preferential tax jurisdictions are always taxed at 20% (Article 682(2)). Shareholder-loan interest is deductible only within a thin-cap formula, with a ratio of 4 for non-financial companies (Article 263).
5. Arrears: penalty interest is charged daily at 1.25 times the base rate (Article 5); the tax authority can freeze account debits and suspend e-invoicing (Articles 86–89). Since July 1, a court may approve a temporary exit ban on the company's head if arrears above the limit remain unpaid for more than three months (Article 189).
6. Limitation period: three years in general and five for large businesses (Article 65); document retention should match.

1. Sample tax forms

The current forms and filing instructions were approved by Order No. 695 of the Minister of Finance of November 12, 2025 (Ministry of Justice registration No. 37390, effective January 1, 2026). Each form is a separate annex to the order, and the samples can be viewed on the order's page on adilet:
100.00, CIT return: Annex 2 (schedules 100.01–100.14)
101.02, CIT advance payment calculation: Annex 3
101.04, CIT withheld at source from non-resident income (including treaty-exempt amounts): Annex 5
200.00, PIT and social tax return: Annex 8
300.00, VAT return: Annex 12 (schedules 300.01–300.08)
700.00, vehicle, land and property tax return: Annex 20 (schedules 700.01–700.03)
701.01, current property tax payments: Annex 21
851.00, current land-use fee payments: Annex 23
The filing rules are in Annex 29. Source: https://adilet.zan.kz/rus/docs/V2500037390

328.00, application for import of goods and payment of indirect taxes, was approved by Order No. 628 of the Minister of Finance of October 28, 2025 (registration No. 37237): https://adilet.zan.kz/rus/docs/V2500037237 . We relied on a search summary and did not retrieve the full text of that order; iris.kz reports that it has since been amended, so check the current version before filing.

Points for a logistics company to watch:
International transport turnover goes on line 300.01.002 and the related input VAT on line 300.01.006.
Exempt forwarding, loading and transshipment belong on 300.02, not on the zero-rate lines.
Payments to non-residents that are treaty-exempt still appear on 101.04; where payments to one non-resident under a currency contract exceed USD 50,000 in a quarter, they are reported non-resident by non-resident (Annex 5).
Foreign employees' PIT is reported per person on form 200.00.

Not applicable or needing separate review: 910.00 (simplified declaration) does not apply here; for 870.00 (fee for negative environmental impact), whether a truck fleet must file depends on facility categories under the Environmental Code, which we did not verify, so ask an adviser.

Secondary sources (not primary authority): templates of forms 100.00 and 200.00 reprinted by PRG, https://prg.kz/document/?doc_id=38965453 and https://prg.kz/document/?doc_id=36716294 . Electronic filing is through the SRC Taxpayer Office, https://knp.kgd.gov.kz (per a reprinted SRC notice).

1. Conclusions

For a company like A Logistics, the check-up points to four priorities. First, zero-rating and forwarding exemptions depend on paperwork: waybills, customs declarations and contracts should be filed shipment by shipment, since missing documents, or hauling only a domestic leg, may lead to 16% VAT; exempt forwarding fees and zero-rated freight go on different schedules. Second, confirm withholding rates and obtain the Chinese residence certificate before paying the parent, not afterwards. Third, turn the calendar above into an annual filing schedule: quarterly forms 300.00, 200.00 and 101.04 by the 15th of the second month after each quarter, annual forms 100.00 and 700.00 by March 31, and 101.02 by April 20, with road transit charges paid trip by trip. Fourth, a move into a special economic zone requires registration in the zone, separate accounting for priority and non-priority income, and no stacking with other CIT reductions (Articles 734–735). Structure and treaty questions are best backed by written calculations from a licensed local accountant.

Disclaimer: this report is general information, not legal or tax advice. Some SRC web pages could not be opened at the time of writing; that content comes from reprints and summaries and was checked against the Code. Application in any specific case should be confirmed by a written SRC ruling and by a licensed local accountant or lawyer.

Sources:
Tax Code of the Republic of Kazakhstan No. 214-VIII of July 18, 2025, https://adilet.zan.kz/rus/docs/K2500000214 (unofficial English translation: https://adilet.zan.kz/eng/docs/K2500000214)
Order No. 695 of the Minister of Finance of November 12, 2025 (tax reporting forms, instructions and filing rules; registration No. 37390), https://adilet.zan.kz/rus/docs/V2500037390
Order No. 628 of the Minister of Finance of October 28, 2025 (form 328.00; registration No. 37237; search summary only), https://adilet.zan.kz/rus/docs/V2500037237
Law No. 308-VIII of June 11, 2026, https://adilet.zan.kz/rus/docs/Z2600000308
Law No. 239-VIII of December 8, 2025 on the 2026–2028 national budget (Article 7, MRP), https://adilet.zan.kz/rus/docs/Z2500000239
Law No. 421-II of June 2, 2003 ratifying the Kazakhstan–China double tax agreement, https://adilet.zan.kz/rus/docs/Z030000421_
Law No. 67-IV of July 5, 2008 on Transfer Pricing, https://adilet.zan.kz/rus/docs/Z080000067_
Akorda, July 18, 2025, https://www.akorda.kz/ru/glavoy-gosudarstva-podpisan-novyy-nalogovyy-kodeks-i-soputstvuyushchiy-emu-zakon-o-vnesenii-izmeneniy-i-dopolneniy-v-nekotorye-zakonodatelnye-akty-respubliki-kazahstan-po-voprosam-nalogooblozheniya-1863237
SRC guidance on CIT, September 4, 2025 (reprinted by PRG), https://prg.kz/document/?doc_id=35442164
Akmola regional tax office, VAT registration, https://akm.kgd.gov.kz/ru/news/postanovka-na-registracionnyy-uchet-po-nds-4-160578
Zakon.kz, September 4 (draft 2027 amendments), https://www.zakon.kz/pravo/6530429-nalogovyy-kodeks-chto-planiruyut-izmenit.html
Vlast.kz, September 4 (draft 2027 amendments), https://vlast.kz/novosti/70764-v-kazahstane-vynesli-na-obsestvennoe-obsuzdenie-proekt-popravok-v-nalogovyj-kodeks.html

The cover is an AI-generated illustration and does not depict a real scene.