Client alert: change affecting VAT and indirect taxes in Kazakhstan under the double tax treaty network

Alert: Change affecting VAT and indirect taxes in Kazakhstan under the double tax treaty network Effective: February 2027

Kazakhstan has revised the interaction between its VAT and indirect tax rules and the country's network of double taxation treaties, with the change taking effect in early 2027. The revision clarifies — and in certain respects restricts — how treaty-based exemptions and reliefs are applied to cross-border transactions involving goods, services, and digital supply, including transactions conducted under the EAEU indirect tax protocol that governs trade between Kazakhstan, Russia, and other member states.

Foreign companies supplying goods or services into Kazakhstan, or receiving cross-border payments from Kazakh counterparties, may find that treaty reliefs they have relied upon are now subject to additional documentation or substantive conditions. Companies operating through Kazakh subsidiaries, branches, or representative offices should also verify whether the change affects the VAT treatment of intercompany transactions and management fee arrangements — areas where Kazakh tax authorities have increased audit activity in recent periods.

Recommended action:

• Review your current cross-border supply and payment structures with Kazakh exposure against the revised rules — specifically whether any treaty-based indirect tax relief remains available on its prior terms.
• Verify that your documentation package (including certificates of tax residency and proof of beneficial ownership where applicable) meets the updated requirements under the relevant bilateral treaty and the EAEU indirect tax protocol.
• If your structure involves both Russian and Kazakh entities, consider whether the cross-border VAT position under the Russia–Kazakhstan framework has changed in a way that requires renegotiation of intercompany pricing or contractual terms.

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[Jurisdictional note: Kazakhstan is a separate sovereign jurisdiction from Russia. This alert is prepared with the assistance of Aigerim Serikbayeva, Contributing Regional Analyst — Kazakhstan. For matters governed by Kazakh law, Vetrov & Partners collaborates with qualified Kazakh counsel. We are a Russian-qualified law firm.]

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

— Aigerim Serikbayeva Contributing Regional Analyst — Kazakhstan · EAEU Trade, Customs and Market Entry vetrovpartners.com/contributions/