Kazakhstan’s AIFC: rules drawn from English law, and no corporate tax to 2066 on listed services.

Kazakhstan’s AIFC: rules drawn from English law, and no corporate tax to 2066 on listed services.

October 29, 2026

Since 2018 a company can register in the Astana International Financial Centre, contract under rules drawn from the law of England and Wales, litigate in English before judges from the common law world, and pay no corporate income tax until 1 January 2066 on the income the Statute names. The Statute names financial services. A company that trades goods, runs a plant, or holds subsidiaries outside the Centre is taxed like any other Kazakh company, and its goods clear customs under the law of the Eurasian Economic Union.

What the Centre gives

Inside the Centre four legal orders act at once: its own, the Republic of Kazakhstan’s, the Eurasian Economic Union’s, and the law of England and Wales from which its Acts are drawn.

The Centre is a territory within the city of Astana, 1,632 hectares under the Presidential Decree of 31 December 2015, in which a special legal regime in the financial sphere applies. The Constitution was amended on 10 March 2017 to allow it (Article 2, paragraph 3-1); the Constitutional Statute of 7 December 2015 fills it. Under Article 4 the acting law of the Centre consists of the Statute, of AIFC Acts “which may be based on the principles, legislation and precedents of the law of England and Wales and the standards of leading global financial centres”, and of the law of Kazakhstan for whatever the first two do not govern. English is the official language of the Centre (Article 15), and a participant’s written transaction is in English unless the parties agree otherwise (Article 20).

The AIFC Court is independent and “not a part of the judicial system of the Republic of Kazakhstan” (Article 13). It has a first instance, a Small Claims Court for claims up to USD 150,000 (about EUR 133,000 at the ECB rate of 30 September 2026), and a Court of Appeal whose decisions are final; proceedings are in English. Its Chief Justice is Lord Burnett of Maldon, Lord Chief Justice of England and Wales until 2023. The Court has exclusive jurisdiction over disputes between participants, between participants and the Centre’s bodies, and with their foreign employees; over any transaction carried out in the Centre under its law; and over any dispute the parties agree to bring to it. It hears no criminal or administrative matter. It is bound by the law of the Centre and “may take into account” its own final judgments and those of other common law courts: English case law is persuasive before it, not binding. A judgment is enforced in Kazakhstan “in the same way, and on the same terms” as a judgment of a Kazakh court, once translated into Kazakh or Russian.

The International Arbitration Centre hears disputes under an arbitration agreement (Article 14). Where the parties have not chosen a seat and the dispute is governed by AIFC law, the seat is the Centre. An award is enforced in Kazakhstan on the same terms as a domestic award, and abroad under the New York Convention, to which Kazakhstan acceded on 20 November 1995.

The tax regime is Article 6, and it is written around an activity. Until 1 January 2066 a participant pays no corporate income tax on income from the financial services listed in the Statute and in the Joint Order of 2020: thirty-four regulated activities, from dealing and investment management to custody, fund administration, trust services, Islamic finance, insurance, and payment systems. The same exemption covers legal, audit, accounting, and consulting services rendered to the Centre’s bodies or to participants that provide those financial services. The listed financial services are exempt from VAT. Foreign employees of such participants pay no personal income tax on the salary earned in the Centre. Any person is exempt from income tax on dividends from, and on the gain on the sale of, shares in a company registered under the Centre’s law, and on securities listed on the Astana International Exchange. For everything else Article 6 opens with the rule: the tax regime in the Centre is the Tax Code of Kazakhstan.

What it means for your regional company

The exemption follows the activity and the presence. The Joint Order conditions it on the participant performing its main activities on the territory of the Centre throughout the tax period, and the Rules on Substantial Presence, in force since 1 January 2022, measure that presence by the income-generating activity, the full-time staff and the expenses kept in the Centre. A company registered in Astana that sells equipment in Tashkent, operates a warehouse in Almaty, or holds a stake in a plant in Shymkent earns none of the listed income and pays Kazakh corporate income tax on what it earns; only the exit, the sale of its own shares or the dividends paid on them, sits inside the exemption.

The customs border does not move. Customs is not among the matters Article 4 allows AIFC Acts to regulate, which are civil, procedural, financial, administrative-procedure, and procurement relationships among participants, bodies and employees. Under Article 5 of the Customs Code of the Eurasian Economic Union the customs territory of the Union comprises the territories of its member states, Astana included, and Article 25 of the Treaty of 29 May 2014 applies the Common Customs Tariff to trade with third parties. Goods bound for the Centre clear as goods bound for Kazakhstan.

Currency control is lighter inside the boundary. Article 5 of the Statute lifts, for participants’ currency transactions in the territory, the registration of capital-flow contracts, the account number for a foreign bank account and the notification of currency transactions. Participants employ foreign nationals without work permits (Article 8), and those employees and their families may hold visas of up to five years (Article 7).

The Court reaches a counterparty only as far as the Statute says. A supplier in Almaty or a distributor in Bishkek that is not a participant comes before the Court by the clause you write, on the forum and on the governing law. Outside Kazakhstan, the Court states that its judgments travel under the CIS conventions on legal assistance and under Kazakhstan’s bilateral treaties; since Article 13 places the Court outside the Kazakh judicial system, whether a foreign court will treat an AIFC judgment as a Kazakh judgment for treaty purposes is a question for counsel in that country before the contract is signed. An award of the International Arbitration Centre carries no such question: 172 states are party to the New York Convention.

What to do, and when

Before incorporation, write down which of the thirty-four listed activities the company will perform in Astana, with which people and in which office. If the answer is none, the tax argument is gone and the Kazakh Tax Code applies to the operating income from the first day.

Choose the route on the same day: incorporate a new entity, register an existing foreign company or partnership as a recognised one, or redomicile. Registration is online; a regulated activity is licensed by the Astana Financial Services Authority first.

In every contract with a party outside the Centre, choose the forum in writing, the AIFC Court or arbitration seated in the Centre, and for each country where the counterparty’s assets sit obtain a written answer on how a judgment or an award will be enforced there. Keep a Kazakh or Russian translation ready: Articles 13 and 14 require it for enforcement in Kazakhstan.

Plan customs duties, VAT on goods and excise under the law of Kazakhstan and of the Union, as for any Kazakh company.

The boundary is drawn around an activity, not around an address.

In brief

Inside 1,632 hectares of Astana, companies, contracts, and disputes live under AIFC Acts drawn from English law, before an English-speaking court whose judgments are enforced in Kazakhstan as Kazakh judgments.

Until 1 January 2066 corporate income tax and VAT are lifted on thirty-four listed financial services and on the professional services rendered to those who provide them, with a substantial presence in the Centre; everything else follows the Tax Code of Kazakhstan.

The customs border is the Union’s; a counterparty outside the Centre comes before the Court only by agreement, and enforcement abroad is checked country by country before signing.

Sources. Constitution of the Republic of Kazakhstan, Article 2, paragraph 3-1, inserted by the Law of 10 March 2017 No. 51-VI. Constitutional Statute of the Republic of Kazakhstan on the Astana International Financial Centre, No. 438-V of 7 December 2015, as amended to 30 December 2022: Articles 1, 4, 5, 6, 7, 8, 13, 14, 15, 19, 20, and 22. Decree of the President of the Republic of Kazakhstan No. 161 of 31 December 2015 (territory of 1,632 hectares), as cited by the Astana Financial Services Authority. Joint Order approving the List of financial services provided by AIFC participants exempt from corporate income tax and value-added tax: Governor of the AIFC No. 126 of 26 May 2020, Minister of Finance No. 547 of 29 May 2020, Minister of National Economy No. 118 of 12 June 2020. AIFC Rules on the Substantial Presence of the AIFC Participants Applying Tax Exemptions, in force from 1 January 2022. AIFC Court Regulations 2017 (structure of the Court, appeals, language of proceedings); AIFC Court, pages on jurisdiction, enforcement, the Chief Justice and the Justices, and the Small Claims Court threshold. AIFC Arbitration Regulations 2017, Articles 30 and 45; AIFC Arbitration and Mediation Rules 2022, Article 15. Treaty on the Eurasian Economic Union of 29 May 2014, Articles 1 and 25; Customs Code of the Eurasian Economic Union, Article 5.
UNCITRAL, status of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958): Kazakhstan, accession 20 November 1995, in force 18 February 1996; 172 parties. AIFC, news release of 19 June 2025 on the 4,000th registered company. Term: special legal regime in the financial sphere (особый правовой режим в финансовой сфере).

Note 1. Why the rule is written the way it is. Kazakhstan’s first financial centre, the Almaty Regional Financial Centre under the Law of 5 June 2006, operated within Kazakh law; Article 22 of the 2015 Statute repealed that Law. The second attempt did not translate Kazakh law for foreign readers. It adopted the readers’ own legal language, a court drawn from it and English as the official language of the territory, and in 2017 the Constitution was amended to make room for it. By June 2025 the Centre’s participants exceeded 4,000 and came from 84 countries, and the ten most represented were China, Russia, the United Kingdom, the United States, Turkey, Singapore, the United Arab Emirates, India, Cyprus, and the Netherlands. Sources: Constitutional Statute, Articles 15 and 22; Constitution, Article 2, paragraph 3-1; AIFC, news release of 19 June 2025.

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This article is general information, not legal advice; it reflects the law as at 29 October 2026.