Create a company in Cyprus — or move your company from Kazakhstan

Kazakhstan replaced its entire Tax Code on 1 January 2026, so nearly every Kazakhstan figure you will read online is now wrong. And the one thing almost every adviser assumes — that the Cyprus treaty keeps a Cyprus company outside Kazakhstan's controlled-foreign-company net — fails on a single word in a single subparagraph. This is that decision, written from the departure side.

Updated for 2026 Cyprus tax law and regulations.

One provider for the Cyprus half of a Kazakhstan relocation

Sumly is the fully digitalized, one-partner way to start a Cyprus company, move a business there from Kazakhstan and operate it from the day the company exists. We register the company, open the books the day your order arrives, prepare every Cyprus return box by box, and run the tax residency and non-dom application as one fixed-price service. One dashboard, one provider, and prices published before you commit. The Kazakhstan half of the move belongs with a Kazakhstan adviser, and we say so rather than pretending otherwise.

This is Sumly — and what we actually do for you

Sumly is the fully digital provider for founders moving a company to Cyprus. You do not need to learn Cypriot company law, find a local auditor, or work out which form goes where. You get in touch, and we do the rest.

And we stay with you on both sides of the move. The Cyprus side we own outright. For the side you are leaving, we put you straight in front of an adviser or lawyer from our network who works on exactly your problem — company law, exit taxation, inheritance, employment — and we hold the thread between them and us. One point of contact for the whole move, however many specialisms your case turns out to touch. If your case is simple, we do all of it for a fixed price.

Part 1: What leaving actually costs you

Your home country does not let go the moment the plane does. What still runs after you have left, and in which order it has to be handled.

Why is almost every Kazakhstan tax figure online now wrong?

Because a whole new Code took over. The instrument is the Tax Code of the Republic of Kazakhstan, Code No. 214-VIII of 18 July 2025, and article 848(1) says that it takes effect on 1 January 2026, with three narrow exceptions timed to July 2026 and January 2027. It replaced the 2017 Code outright. Anything researched before mid-2025 — which is most of what ranks — describes a system that no longer exists.

Here is what actually moved, article by article:

The corporate schedule is the part that surprises people who last checked in 2024. Article 357(2) now sets 3% for agricultural production, 6% for agricultural cooperatives, 5% for the social sphere in 2026 rising to 10% from 1 January 2027, 25% for second-tier banking and for casinos, slot halls, totalisators and bookmakers, and 20% for everything else. Ordinary founders are on the 20% line, but the schedule is real and it has a dated increase already written into it.

Almost every threshold in Kazakhstan tax law is expressed as a multiple of the MRP, the monthly calculation indicator, which the annual budget law resets each January. For 2026 it is 4,325 tenge, alongside a minimum wage of 85,000 tenge. Two traps follow. The first is that different articles fix the MRP at different moments — the personal income tax scale uses the value in force on 1 January of the financial year, while social tax for a sole trader uses the value on the payment date. The second is that every tenge threshold in this guide changes next January, because the multiplier stays and the multiplicand moves. Euro equivalents below use a rate of roughly 540 tenge to the euro and are indicative conversions only, not legal figures.

Does moving to Cyprus actually cut a Kazakhstan founder's tax bill?

By about five points at the company, and almost nothing at the shareholder — until you actually relocate. That is the honest answer, and a guide that opens with a bigger promise is selling you something.

Kazakhstan's ordinary corporate rate is 20%. Cyprus charges 15% from tax year 2026, up from 12.5% before its own reform. Five points is real, and it is not on its own a reason to restructure a working business. On dividends the two systems have converged: Kazakhstan charges an individual 5% on ordinary amounts, and after the Cyprus reform a Cyprus-domiciled shareholder pays 5% on dividends from 2026 profits as well. On VAT, Kazakhstan is cheaper: 16% against the Cyprus standard rate of 19%.

So where does the difference actually live? In the shareholder position, and only for someone who genuinely moves. A Cyprus tax resident who is not domiciled in Cyprus pays no Special Defence Contribution on dividends for 17 years and no income tax on them either, leaving only the health contribution at 2.65% on income up to €180,000 a year. Get profit out of a Kazakhstan company to its individual owner and the combined cost is 20% at the company and 5% on what remains — about 24% all in. Through Cyprus, for a founder who has genuinely arrived, it is 15% and then a capped health contribution.

That is the whole tax case. It is a decent case, and it is a much smaller one than the corridor's marketing suggests. If your customers, your banks and your money are already in Europe, read on — the rest of this page is about the things a rate comparison never captures.

What does Kazakhstan's personal income tax cost now that it is not flat?

More than the famous number, and the correction matters most to founders who pay themselves properly. Article 363(1) sets 10% on taxable income up to 8,500 MRP and 15% above it, with the MRP taken as at 1 January of the year. At the 2026 MRP that band ends at 36,762,500 tenge, roughly €68,000 of taxable income. Above it, every extra tenge is taxed at 15%.

The dividend line carries the repeal that costs founders the most. Article 363(3) taxes individual dividend income at 5% up to 230,000 MRP and 15% above — about 995 million tenge, so the 5% band is generous. But the old exemption for dividends on shares held more than three years is simply gone. It is not in article 255, not in article 337 and not in article 681. What still carries a three-year test is a capital-gains relief at article 337(2)(7), covering shares and participation interests in Kazakhstan-resident issuers and Kazakhstan consortia, excluding subsoil users and companies where subsoil-user property exceeds half the assets. That relief does not travel: it will never shelter the sale of a Cyprus company. Confusing the two is the easiest way to plan a disposal on a rule that no longer exists.

Corporate recipients are treated differently and generously. A Kazakhstan company receiving dividends from another Kazakhstan company reduces its gross annual income by the full amount of the dividends — no minimum stake, no holding period, and no withholding on the way out either.

Payments to non-residents run on their own scale. Article 682(1) charges 15% on dividends, capital gains and royalties, 10% on interest on loans and debt securities, and 20% on the residual category, with a 5%-then-15% scale for a holder of at least 25% of the paying company's capital, directly or indirectly. And article 682(2) overrides all of it with a flat 20% for anyone registered in a listed low-tax state, whatever paragraph 1 would otherwise give.

Which Kazakhstan special regimes survived 2026, and which are gone?

Three survived out of five, and two of the ones founders ask about most were abolished outright. Section 16 of the 2026 Code now contains exactly three chapters: the self-employed regime, the simplified declaration, and the peasant or farm regime. The retail tax is gone — the phrase does not appear once anywhere in the Code — and so is the patent regime.

The simplified declaration is the one a small Cyprus-bound founder is most likely to be sitting on. Eligibility under article 723 caps annual income at 600,000 MRP, about 2.6 billion tenge, which is a large ceiling by regional standards. But article 723(2) bars a legal person where other legal persons hold more than 25%, bars founder overlaps between two companies both using a special regime, and bars participants in special economic and industrial zones and in Astana Hub. The rate under article 726 is 4%, which the local maslikhat may move by up to 50% in either direction — so anywhere from 2% to 6% depending on the district, decided by 1 December of the preceding year. The base is gross receipts, not profit, which is the part people forget until the first return.

The self-employed regime charges 0% individual income tax, and it is worth stating plainly what that headline hides: article 718(2) restricts it to Kazakhstan citizens and kandas — ethnic Kazakh returnees — with no employees and monthly income under 300 MRP, on a government-approved activity list, through a mandatory app. Social payments are still due. It is not a route for a foreign founder and it is not a "0% Kazakhstan" story.

One thing this Code does not contain at all is a tax on accumulated wealth. Article 201 is an exhaustive enumeration of every tax and budget payment Kazakhstan levies, and it lists corporate and individual income tax, VAT, excise, export rent tax, subsoil-user payments, social tax, vehicle tax, land tax, property tax and gambling tax. There is no net wealth tax, no inheritance tax and no gift tax on that list, and the words for them return nothing in the text. Cyprus levies no net wealth tax and no inheritance tax either — so on this axis the move changes nothing, and anyone selling Cyprus to you as estate planning against a Kazakhstan wealth tax is describing a tax that does not exist.

What does exist is a steeply progressive residential property tax with a luxury coefficient built into the valuation formula. Article 602 runs a long ladder that starts at 0.05% and finishes at 2% on value above 450,000,000 tenge, and article 601 aggregates all of a person's properties once that ceiling is passed. For a founder with substantial Almaty or Astana property, that is the closest thing Kazakhstan has to a wealth charge — and it stays behind when you leave, because it follows the asset and not the owner.

Does Kazakhstan charge an exit tax when you leave?

No. There is no deemed disposal on emigration, no departure charge, no exit return and no analogue of the German or Swiss departure regimes. We searched the consolidated 2026 Code for the concepts that would have to appear — loss of tax residency, cessation of residency, departure for permanent residence abroad — and there are none. Residence is a status test under article 222 that simply stops being met, after which article 221 switches you from worldwide to Kazakhstan-source taxation. This is a verified absence rather than an assumption, and we are not going to cite an article number for it, because there is none to cite.

What follows you out is filing exposure, not a charge, and it is heavier than founders expect. The annual declaration of income and property under article 417 is triggered, for anyone resident for the period, by money in foreign bank accounts exceeding 1,000 MRP in aggregate at 31 December, ownership of a participation interest in the charter capital of a legal person registered outside Kazakhstan, ownership of digital assets, and acquisitions during the year with a combined value above 20,000 MRP. Read the second of those again: a stake in a foreign company triggers the declaration at any value, with no threshold at all. The foreign-bank trigger is 1,000 MRP, roughly €8,000 — low enough that a single euro account clears it. A Kazakhstan resident who incorporates in Cyprus is inside this regime from the first day, and it applies whether or not the Cyprus company is ever a CFC. Those are two separate obligations and people routinely conflate them.

Do Kazakhstan's CFC rules catch a Cyprus company?

They can, and the reason is a boundary condition that did not exist before 2026. This is the most valuable section on this page and the one no competing result covers.

Chapter 33 of the Code taxes the profit of a controlled foreign company. Article 332(1) defines one with three limbs that must all be satisfied at the same time: the entity is a non-resident legal person or foreign organisational form and does not fall inside the treaty carve-out; at 31 December of the reporting period a Kazakhstan resident holds 25% or more directly, indirectly or constructively, or controls it; and either its effective profit tax rate is below 10% or it sits in a state on Kazakhstan's low-tax list.

Work limb one. The carve-out spares a company registered in a state with a double tax treaty in force provided that the nominal profit tax rate in that state is more than 75 per cent of the Kazakhstan corporate income tax rate under article 357(2)(5). That Kazakhstan rate is 20%. Seventy-five per cent of twenty is fifteen. The statute says more than, so the foreign nominal rate has to exceed 15%.

Two qualifications belong with that, and the guide would be dishonest without them. First, failing the carve-out does not make anything a CFC — it only means Cyprus companies are not excluded at the door, and limb three still has to be met. Second, article 332(1)(1) delegates the actual list of qualifying treaty states to the authorised body, to be approved no later than 31 December of the year following the reporting period. That is up to twelve months in arrears, so the administrative position for a given year may not be settled until the following December. We could not locate a published list under that provision on either Adilet or the State Revenue Committee's site. So: state the arithmetic, and put the administrative question in writing to the tax authority before you rely on either answer.

Now limb two, which is broader than the 25% number suggests. The threshold counts holdings directly, indirectly or constructively, and article 332(3) defines control by reference to International Financial Reporting Standards or other internationally recognised reporting standards, not by percentage at all. A resident with a 10% stake and a shareholders' agreement giving him power over the relevant activities can be caught with no 25% test in sight. And constructive ownership aggregates a resident's holdings with those of close relatives — a list that runs to spouse, children including adopted, the spouse's children, grandchildren and the spouse's grandchildren, dependants and the spouse's dependants, parents and the spouse's parents, full and half siblings and the spouse's siblings. Splitting a Cyprus company between yourself and a brother does not work. Ownership is measured on one day: 31 December.

Limb three is where Cyprus actually lands, and the news is mixed. Kazakhstan's low-tax list for 2026 was approved by Order No. 492 of 12 September 2025, in force from 1 January 2026, which repealed the 2018 list. It runs to 56 states and territories. Cyprus is not on it — Malta is, and Hong Kong and Macau are, via the China entry. So the automatic route into limb three is closed, and everything turns on the effective rate.

That effective rate is not the 15% headline. Article 332(3)(3) defines it as an arithmetic mean of the effective profit tax rates for the reporting period and the two preceding periods, with loss-making periods dropped from the calculation — that is, tax actually paid over accounting profit, averaged across three years. Cyprus is full of perfectly legitimate reliefs that depress it: the IP Box, the participation exemption on dividends received, group relief, notional interest deduction on new equity. Income qualifying under the IP Box reaches an effective 3% from tax year 2026. A Cyprus company running most of its income through the IP Box can quite ordinarily post a three-year average below 10% — and at that moment it becomes a CFC of its Kazakhstan-resident owner and its profit is taxed in Kazakhstan at 20%.

Read that inversion carefully, because it is the opposite of what everyone expects. The better your Cyprus tax position looks, the more likely it is to make you a Kazakhstan CFC — because Kazakhstan measures the rate you actually paid, not the rate on the statute book.

Three ways out, and they are not equal. The de minimis in article 332(2) is unusable: it applies only where gross income is under 195 MRP, about 843,000 tenge, measured per company and unavailable to anything in a listed offshore state. Assume it does not help you. The loss rule in the same paragraph is more useful — a company that reports a financial loss for the period in its approved separate non-consolidated financial statements is not a CFC for that period at all. And the real exemption is article 334(1)(5), which exempts the profit where the share of passive income is less than 20 per cent. A genuine trading company in Cyprus with staff, customers and service revenue should clear that comfortably. A holding company will not. An IP-licensing vehicle is precisely the case to have checked rather than assumed: we are not going to assert here which side of the passive-income definition a given royalty stream falls, because that definition needs reading against your actual contracts. Article 334 also requires the exemption to be evidenced — group structure charts, approved financial statements, statements signed by the company's first officer — all with mandatory translation into Kazakh or Russian.

When the charge does land, article 335 computes it as the sum across every controlled company of each one's positive financial profit multiplied by the resident's direct, indirect or constructive share, taken from approved separate non-consolidated financial statements prepared either to the standard of the company's own country or to IFRS — and IFRS only where audited statements exist. A company's losses from the two immediately preceding periods can be carried into that computation, but one company's loss can never reduce another's profit or your own taxable income, and losses of companies registered in listed low-tax states cannot be used at all. There is also a consistency rule people miss: elect the passive-income formula for one controlled company and you must apply the same formula to every other one you hold for that period. Foreign tax paid is creditable.

The other exemption worth naming is article 334(1)(6), which exempts a CFC held or controlled by an AIFC investment resident entirely. That is a domestic alternative to leaving, and it is discussed below rather than buried.

What happens if a Kazakhstan founder simply does not file the CFC statement?

The authority makes the finding for you. Article 336(1) requires a resident to file the statement of participation in, or control of, a controlled foreign company by 31 March of the year following the reporting period, as at 31 December of that period, to the tax office of your residence or location. The form for 2026 is the one approved by Order No. 536 of 25 September 2025, in force from 1 January 2026, which repealed the 2018 order. If someone hands you a pre-2026 form code, it belongs to a repealed instrument.

Two things follow. The burden of disproof sits on the taxpayer, not on the authority. And the trigger is a data feed, not an audit lottery — Kazakhstan participates in automatic exchange, and a Cyprus company with a Kazakhstan-resident beneficial owner is visible. Where the financial statements are not approved in time, article 359(4) provides a purpose-built extension: the CFC profit goes into a supplementary corporate income tax return within sixty working days of the statements being approved, and no later than 31 March of the second year following the reporting period.

When does Kazakhstan tax residency actually end?

Later than most people plan for, and on two independent tests. Article 222(1) makes an individual resident by permanent presence or by centre of vital interests, and each has a trap in it.

Permanent presence means at least 183 calendar days, including days of arrival and departure, in any consecutive twelve-month period ending in the tax period — a rolling window, not a calendar year. Leaving in July does not reset anything; the window keeps sliding until 183 days no longer fall inside it. Note also that the same paragraph sets the threshold at ninety days for an AIFC investment resident, which cuts against anyone trying to leave while holding that status.

The centre-of-vital-interests test is where the Russian-language internet is most misleading, and the truth is favourable to you. Article 222(3) treats the centre as being in Kazakhstan only on simultaneous satisfaction of three conditions: Kazakhstan citizenship or a residence permit; spouse and close relatives living in Kazakhstan, where there are any; and Kazakhstan immovable property owned or otherwise available at any time for the person or those relatives to live in. All three at once. Break any single limb and the test fails. Almost every secondary source writes it as though any one limb sufficed, which convinces readers they cannot leave. In practice the limb a departing founder controls is the third — selling the flat, or putting it on a genuine long lease, is a substantive act and not paperwork. And citizenship alone never makes you resident here, because it is only one of three cumulative conditions.

Article 222(4) then hard-codes residence regardless of days for a defined list of Kazakhstan citizens abroad, and one entry catches founders: people abroad for study, internship, treatment or research and teaching are treated as resident for the duration. A founder who leaves for a master's degree stays a Kazakhstan tax resident throughout it, whatever the day count says.

One practical instruction before you go. Pull a tax residence certificate for your final full Kazakhstan year while the file is clean and the local office still has you on its books. From 2026 the certificate is issued only for use outside the Republic of Kazakhstan, it comes from the tax office superior to the one where you are registered, and it can cover the past and/or the current calendar year. The processing time and fee are set by subordinate rules we did not retrieve, so ask at the point of application rather than trusting a figure you read somewhere.

Will a Cyprus company run from Kazakhstan become a Kazakhstan company?

Yes, and Kazakhstan's test is unusually concrete about how. Article 223(1) makes a legal person resident either by incorporation in Kazakhstan or by being incorporated abroad with its place of effective management in Kazakhstan — and article 223(2) defines that place as where the meeting of the actual governing body, the board of directors or an equivalent organ, is held and where management, control and the decisions needed to run the business are taken.

Signing minutes in Limassol while the decisions are taken in Almaty is exactly the fact pattern that article is drafted for. A Cyprus company whose board really meets in Kazakhstan is a Kazakhstan tax resident, taxed on worldwide income. The Cyprus structure works only with real management substance in Cyprus: decisions taken and minuted on the island, material commitments approved there, and a documentary record that matches the reality. Our guide to nominee directors in Cyprus sets out what a nominee does and does not solve, and it does not solve this.

The rule cuts the other way too, which founders find counter-intuitive. A Kazakhstan company stays Kazakhstan-resident by incorporation even after you have gone — moving the founder does not move the company. If its board then starts meeting in Cyprus, Cyprus asserts management-and-control residence as well and you have a dual-resident company to resolve under the treaty tie-breaker.

What should you do with the Kazakhstan company itself?

Choose deliberately between two options, and avoid the third by default. Keep it as a genuinely Kazakhstan-managed company with a real board in Kazakhstan and treat Cyprus as a separate operating company. Or wind it up cleanly and start fresh. The drifting middle — a Kazakhstan company quietly run from Cyprus — is the worst of all three: dual residence, a CFC analysis running in the wrong direction, and a liquidation audit waiting whenever it eventually ends.

Winding up is not a quiet exit. The obligation to file liquidation tax reporting arises within three working days of approval of the interim liquidation balance sheet, and the filing is itself a ground for tax administration including a tax audit. Three working days catches people who imagine liquidation as a leisurely process, and the audit exposure is the price of the clean exit. Where the liquidating taxpayer's assets do not cover the debt, article 75(3) passes the remainder to the founders in the cases Kazakhstan law provides for. A sole trader has it tighter still: article 76 requires the cessation application and liquidation reporting together within thirty calendar days of the decision to cease, and deregistration is blocked not only by arrears but also by overpaid amounts awaiting refund, which is a surprisingly common hold-up.

If you keep the company, distributions out of it to you as a now-non-resident are taxed under article 682(1)(6) — 5% up to 230,000 MRP if you hold at least 25%, then 15% — or at the treaty rate, which for a qualifying corporate holder is better. On moving the company itself rather than replacing it: no Kazakhstan instrument permitting outbound corporate continuation into Cyprus was located, so we are not going to describe a redomiciliation route as if it existed. Put it to the Kazakhstan registrar and the Cyprus Registrar as a question, and plan on incorporation plus liquidation until someone answers it in writing.

What does the Kazakhstan–Cyprus treaty actually give you?

A working treaty, in force since before the pandemic, with one clause that does real rate work. It was ratified by Law No. 298-VI of 30 December 2019, and Cyprus's own treaty table records signature on 15 May 2019 and entry into force on 17 January 2020.

The clause that earns its keep is article 10(2)(a). The treaty's 5% dividend rate needs only a 10% direct corporate holding, whereas Kazakhstan's domestic 5% band under article 682(1)(6) needs 25% and then runs out at 230,000 MRP. Between a 10% and a 25% holding the treaty is straightforwardly better, and above the domestic band the treaty caps a qualifying corporate holder at 5% where domestic law would charge 15%. For an individual shareholder the position reverses — the treaty's 15% is worse than the domestic 5% band — and since applying a treaty rate is an option rather than an obligation, you take the domestic rate. This is one of the few corridors where reading the treaty carefully changes the number.

Two clauses to check before building anything. Article 12 covers software payments expressly, so a licence fee flowing from Kazakhstan to a Cyprus IP company meets a 10% source tax under the treaty, which is a real cost that royalty-routing plans often forget. And article 29 is a principal purpose test in modern form: benefits are denied where obtaining the benefit was one of the principal purposes of an arrangement, unless granting it accords with the object and purpose of the provision. A Cyprus entity in this corridor needs real people, real decisions and a real commercial reason to exist — which is the standard it should meet regardless of any anti-abuse article.

Can a Kazakhstan founder move money out freely?

This is the honest heart of the corridor, and it is a compliance argument rather than a tax one. Kazakhstan is not a closed-currency country and the tenge is convertible. What it has is a reporting and repatriation architecture sitting on top of every cross-border contract, and for a founder whose whole revenue is foreign-currency B2B service income, that architecture is the daily friction a rate comparison never captures.

Start with repatriation. Under the currency law, a resident must ensure the repatriation of national and foreign currency within the periods provided by the export or import currency contract, and the contract itself must state deadlines for the non-resident's performance — with the servicing bank entitled to require the resident to tighten them. Money earned abroad is not yours to leave abroad, and the paperwork says so in advance. Proceeds credited to foreign accounts must be transferred back to an account at an authorised bank before the repatriation deadline expires.

Then the accounting number. For capital-movement currency contracts, article 14 requires the resident to apply to the National Bank for an accounting number before performance of the contract begins by any party — and where the non-resident performs first, before the money or property reaches the resident. Currency operations under a contract that requires an accounting number are simply not processed without one. Registration takes five working days from a complete document package, and foreign-language documents must be submitted with a Kazakh or Russian translation. The monetary threshold above which a contract needs a number is not in the statute at all; article 14(5) delegates it to the National Bank's monitoring rules, so it can move without a change in the law. Check the current threshold before you sign anything, and do not plan on a number you read in an article.

That is the thing a euro-denominated Cyprus company simply does not live inside. No currency contract with a mandated performance deadline, no central-bank accounting number obtained before the money moves, no five-working-day lead time, no mandatory translation file, no bank refusing an operation for want of a registration. This, and not five points of corporate tax, is the strongest Kazakhstan-specific argument for the move. The requirement is penalty-backed and monitored jointly by the tax authority and the National Bank; the penalty schedule sits in the administrative offences code, which we did not retrieve, so we are not printing a fine.

One exception worth knowing before you conclude that leaving is the only answer: article 14(6) puts currency operations conducted by AIFC participants on AIFC territory outside this regime entirely.

Are the AIFC and Astana Hub better than leaving Kazakhstan?

Sometimes, and an honest guide names the domestic alternatives instead of pretending Cyprus is the only answer. Both, though, are narrower than their reputations.

The Astana International Financial Centre's corporate exemption is confined by its own constitutional statute to a closed list of financial services — Islamic banking, reinsurance and insurance broking, investment fund management and custody, brokerage, dealing and underwriting — plus legal, audit, accounting and consulting services rendered to those participants. A SaaS company, an agency or an e-commerce business inside the AIFC does not get that exemption. The widely repeated "0% until 2066" headline is true only for the listed activities. What the AIFC does give an ordinary founder is real and specific: the CFC exemption at article 334(1)(6) for holdings by an AIFC investment resident, and the currency-control exclusion above. Set against that, the ninety-day residence threshold in article 222(2)(2) makes an investment resident a Kazakhstan tax resident far more easily than everyone else.

Astana Hub is the one aimed squarely at technology founders. Its participants reduce the calculated corporate income tax by 100 per cent on intellectual property income, information-technology service income and other income, subject to the eligibility conditions in article 17 — registration with the cluster fund and at least 90% of gross annual income from priority ICT activities. Article 739(4) is the cliff: fall out of the conditions and you revert to the general regime from the start of the tax period in which the breach occurred, retrospectively for the whole year.

And there is a date on it. Article 848(2) confines article 17 and its associated reliefs to operation until 1 January 2029. A founder relying on Astana Hub for a ten-year plan is relying on something with a three-year statutory horizon. Check for an extending instrument before you decide — it may well come — but plan for what the statute currently says.

Part 2: What Cyprus gives you

This is the straightforward half, and the half we build end to end. What you actually get on the other side.

What does the Cyprus side look like for a Kazakhstan founder?

One rate, one set of returns, and a shareholder position that rewards genuinely arriving. A Cyprus limited company pays 15% on taxable profit with no activity schedule and no bands, and qualifying income under the IP Box reaches an effective 3% — which is where the difference against Kazakhstan's 20% stops being marginal, and, as the CFC section explains, exactly where the Kazakhstan analysis has to be closed first. Cyprus personal income tax climbs in steps, from 0% to €22,000 rising to 35% above €72,000, which is why a director's salary and a shareholder's dividend sit on completely different footings here. VAT registration becomes compulsory above turnover of €15,600.

Cyprus levies no net wealth tax and no inheritance tax, exactly as Kazakhstan does not — so nothing on that axis is a reason to move. What changed in Cyprus in 2026 is worth knowing while you compare, because Cyprus's settlement is not static either: the corporate rate rose from 12.5% to 15%, the tax on actual dividends fell from 17% to 5%, deemed dividend distribution and stamp duty were abolished, and loss carry-forward was extended to seven years. The full picture is in what the 2026 Cyprus tax reform changed, the shareholder mechanics are in Cyprus non-dom status, and the IP Box is at the IP Box service page.

How does a Kazakhstan founder become Cyprus tax resident?

Either on 183 days, or on the 60-day rule — and the 60-day route lost a condition in 2026. Four now apply, since the fifth was removed from the 60-day rule: at least 60 days in Cyprus, no more than 183 days in any other single state, a business, employment or office in a Cyprus tax-resident person held through the year, and a permanent home in Cyprus owned or rented.

The condition that disappeared — not being tax resident anywhere else — was precisely the awkward one for someone leaving Kazakhstan, because the rolling twelve-month window in article 222(2) can keep you Kazakhstan-resident well past the day you land. Its removal means that overlap no longer disqualifies you from Cyprus residence by itself; the two claims resolve under the treaty's article 4(2) ladder instead — permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. The office the third condition asks for can be your directorship in the Cyprus company, so incorporation and residency run as one project rather than two.

On immigration, the honest position: the Yellow Slip is a registration certificate for EU citizens exercising free movement under EU law, and Kazakhstan is not an EU member state, so it is not the Kazakhstan route and we promise nothing about it. Kazakhstan founders use the routes open to third-country nationals; we handle our side of the paperwork and bring in immigration specialists where the file needs them. The day counting is set out in the Cyprus 60-day rule.

Why do people choose Cyprus over other tax havens?

Because it is a country people want to live in, and most of the low-tax alternatives are places you visit a bank. For a Kazakhstan reader the tax case is narrow, so the rest has to be specific and honest.

Violent crime here is among the lowest in the European Union. The island runs in English across business, banking, contracts and professional services, which removes the biggest practical friction in moving anywhere in Europe. People from every part of the world are already here, so an arriving founder is never the only foreigner in the room. Business and real estate are booming. Officialdom starts from the assumption that trade is normal rather than that it needs permission. Groceries — meat, fruit, vegetables — are affordable. And the sea: even a Cyprus winter has an afternoon at the beach in it, while the summers are what people fly across continents to reach.

The Kazakhstan-specific case, stated without inflation:

1. Currency freedom. No repatriation requirement, no currency contract with a mandated performance deadline, no accounting number obtained from a central bank before money moves. This is the argument, and it is a compliance one.
2. EU membership. A Cyprus company establishes and sells across 27 member states and enforces its contracts under EU instruments. Kazakhstan is in the Eurasian Economic Union, which is a real common market — but it is the Russia-facing one, and for a founder selling into Europe it is the wrong one.
3. An EU VAT number visible in VIES. European business customers reverse-charge against a VIES-listed number without thinking about it. A Kazakhstan supplier is a third-country vendor with an extra procurement step attached, and some EU buyers decline outright.
4. Euro banking inside SEPA, with an IBAN European counterparties and payroll systems accept without a currency-contract file behind it.
5. Statutory horizons. Kazakhstan's most attractive regimes for technology founders carry expiry dates written into the Code itself: Astana Hub's basis to 1 January 2029, the social-sphere corporate rate doubling on 1 January 2027, the reduced VAT on medicines rising the same day.
6. A settlement that has just moved a long way. Inside eighteen months Kazakhstan replaced its Tax Code, raised VAT by four points, ended the flat personal rate, abolished the retail and patent regimes, published a new offshore list and a new CFC form, and amended the currency law again in January 2026. Both jurisdictions are moving — Cyprus reformed in the same window — but a founder choosing a base for the next decade should price that in rather than assume stability.

Against all of that, one counterweight no relocation page will offer you. If your customers, suppliers or logistics are eastward — inside the Eurasian Economic Union, with its customs treatment running through the Code's VAT provisions — then moving the company to Cyprus is a straightforward loss, and you should not do it.

Can a Kazakhstan e-commerce brand sell into the EU through Cyprus?

Yes, and for a store the single-market question outweighs the tax one by a distance. A Kazakhstan company selling into the EU is a third-country seller: customs formalities, import VAT, and none of the union-wide simplifications a member-state seller uses without thinking. A Cyprus company sits inside the EU VAT system with a number buyers verify in VIES, zero-rates intra-EU business sales, and uses the one-stop shop for consumer sales across the bloc. Putting the store back inside the single market is the reason; the rate difference is a rounding error beside it.

The ledger is where stores actually come unstuck, because thousands of small transactions in several currencies carry a VAT treatment that changes by customer type and destination country. Sumly's Shopify and WooCommerce plugins pull orders, refunds, fees and payouts into the books with the right codes as they arrive, so the VAT return is built from trading rather than reconstructed from a spreadsheet at quarter end.

Two worked examples

A consulting company distributing profit to its Kazakhstan owner. On €200,000 of profit, Kazakhstan takes 20% at the company — €40,000 — and then 5% of the €160,000 distributed, another €8,000. That is €48,000, about 24% all in, and the 5% band is nowhere near its 230,000 MRP ceiling. Through a Cyprus company owned by a founder who has genuinely become Cyprus tax resident and non-domiciled: 15% at the company is €30,000, and the €170,000 dividend meets no Special Defence Contribution and no income tax, only the 2.65% health contribution inside the €180,000 ceiling — about €4,505. Roughly €34,500 against €48,000. The corporate leg saves five points; the shareholder leg is where the rest lives, and it exists only if the shareholder actually moves.

A software company with qualifying IP — and the same numbers done wrong. On €500,000 of profit running mostly through the Cyprus IP Box, the Cyprus charge lands near an effective 3%, so roughly €15,000. Now suppose the founder has not finished leaving: still a Kazakhstan tax resident under article 222, holding more than 25% at 31 December. Cyprus is a treaty state whose nominal rate is exactly 15%, so the carve-out does not reach it; Cyprus is not on the low-tax list, so limb three turns on the effective rate — and a three-year average near 3% is comfortably under 10%. The company is a CFC, its financial profit attributed to the founder's share is taxed in Kazakhstan at 20%, and credit for the Cyprus tax paid takes the sting off but not the charge. The IP Box saving is the very thing that triggers the Kazakhstan liability. Order of operations is the whole ballgame here: end the Kazakhstan residency, then optimise the Cyprus position — never the other way round.

Both examples use headline rates and assume full distribution. Your own thresholds, reliefs, ownership percentages and residency dates change the answer, which is what the meeting is for.

Part 3: How the move runs

From the decision to the first invoice out of the Cyprus company: the order, the mistakes people make before you, and two calculations worked through in full.

What does the move look like, month by month?

Circumstances differ, so treat this as shape rather than schedule.

• Before anything else — and this is where we start. We map the rolling twelve-month window in article 222(2) against your actual travel with you, and settle which limb of the centre-of-vital-interests test you are going to break. Your Kazakh adviser pulls the residence certificate for your last full year.
• Month one. We incorporate in Cyprus, with the ledger open the day the order is placed, and get banking and EU payments moving. If a Kazakhstan company is staying, we settle with you now who sits on its board and where they meet — that decision does not survive being postponed.
• Months one to three. We get you onto VAT and VIES, add the social insurance and employee registrations if you will be hiring, and file the beneficial-ownership record. You take up the directorship that anchors the 60-day rule.
• Months two to six. You rent or buy the permanent home the 60-day rule requires, and we tell you what qualifies. You move real decision-making to Cyprus — which is also what keeps article 223(1)(2) away from the Cyprus company — and we minute it. If the Kazakhstan company is being wound up, your adviser starts it, expecting the audit that article 75(2) invites.
• By 31 March each year. Your Kazakh adviser files the CFC statement on the Order No. 536 form for any year in which you were a Kazakhstan resident holding a foreign company, and the declaration of income and property if any of the article 417 triggers applied. A partial filing is treated as no filing for the company left out, so we check the list against ours before it goes.
• From month twelve. Once you are through the first clean year on the Cyprus side of article 222, we request the Cyprus tax residency certificate and file the non-dom registration behind it.

What mistakes do Kazakhstan founders make?

The expensive ones repeat, and most of them start with an out-of-date page.

Planning on a flat 10% personal rate that ended on 31 December 2025. Planning a share sale on a three-year dividend exemption that was repealed, when the surviving three-year rule is a capital-gains relief for Kazakhstan-resident issuers only. Assuming the treaty with Cyprus disposes of the CFC question, when the carve-out asks for a nominal rate above 15% and Cyprus is at 15%. Building the IP Box first and finishing the residency exit second, which is the ordering that converts a Cyprus saving into a Kazakhstan charge. Splitting shares with a sibling to duck the 25% threshold, when constructive ownership aggregates eleven categories of close relative. Treating the 195 MRP de minimis as an escape hatch when it is under a thousand euros. Forgetting that any stake in a foreign company triggers the article 417 declaration at any value, entirely separately from the CFC statement. Leaving in July and assuming the count restarts in January, when the twelve-month window rolls. Running a Cyprus company from Almaty and calling the Limassol minutes substance. And treating liquidation of the Kazakhstan company as an administrative formality, when the filing is a statutory ground for an audit and the clock is three working days.

Part 4: Who does the work

You can do all of this yourself. Below is what that costs in time and in money, against what it costs to let us do it.

Do it yourself — or have Sumly do it

There are two honest routes here, and what separates them is how much you are willing to carry yourself. Alone, it is the Registrar's forms and fees, a registered office you have to source, VAT and VIES registration, provisional tax twice a year, annual statements and a ledger that has to satisfy an auditor — all of it running beside a departure from Kazakhstan you are already managing. With Sumly it is three prices you can read in advance: formation from €950 one-time, the bookkeeping software from €39 a month and a Sumly certified bookkeeper at €390 a month, with the books open from day zero and every return prepared box by box.

The software on its own runs the company from Cyprus or from Kazakhstan: invoicing, AI double-entry bookkeeping, live open-banking feeds, every VAT, VIES, provisional and corporate return prepared box by box, live reports, a document inbox with its own email address, mobile receipt capture that books itself, multi-currency invoicing, team roles and the AI assistant — plus payroll at €15 per employee per month, IP Box tracking at €50 a month, Projects at €10 a month, and the e-commerce plugins.

Everything else in the catalogue is open to every client: a virtual address with PO box and digital scanning of your post into the dashboard wherever you are; nominee director and secretary where a structure genuinely needs them; tax residency and non-dom at €750 per person; the registrations bundle for VAT, social insurance, employees and UBO; audit through Partner Auditors; the store plugins; banking and EU payments; and the expert-lawyer network for complicated relocations. The Yellow Slip is on that list too — for EU citizens, which is not the Kazakhstan route.

Each of those is an extra, scoped to your case. Tell us what it needs in the meeting and it comes back as one clear package-deal offer covering all of it — the IP Box application included where it belongs, since it is complex expert work that should be examined with you before anyone attaches a price to it.

Sumly, a law firm, and a traditional bookkeeping firm

Law firm vs Sumly — and what happens when a case gets complicated

Sumly is cheaper and faster, and we work WITH lawyers, not against them. When a case gets too complicated for what Sumly handles directly, we simply connect you with the right expert in exactly the legal field you need help in, and everything gets done according to best practice, always. Either way, it starts the same place: contact us.

The Kazakhstan half of this move — the CFC statement above all — belongs with a Kazakhstan adviser, and we will say so every time. The Cyprus half is one provider, one dashboard and four prices you can read before you commit. That is what makes Sumly the best choice for Kazakhstan founders creating a company and relocating to Cyprus.

Why is Sumly the best bookkeeping system for a Cyprus company?

Sumly is the best accounting software for a Cyprus limited company — because it is built for exactly one thing, Cyprus tax law: all 16 Cyprus VAT codes mapped to the official VAT return boxes, VIES and provisional tax native, not a localization. That claim is defensible anywhere, and the table below is why.

The two Cyprus-built alternatives a Kazakhstan founder will be shown are Cybooks and Balabook. We meet their former customers every week, and what they tell us, again and again: workflows that made simple bookkeeping overly complicated, rough edges and glitches, support that left them waiting — a messy experience they were relieved to leave behind.

On every one of these checkable dimensions, Sumly leads. That is a factual comparison — not a matter of taste.

Said plainly: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper and the best prices, with all of it easy to actually do. The detail is published in Sumly vs Cybooks and Sumly vs Balabook, and for the international tools a Kazakhstan founder may already use, Xero, QuickBooks and Sage.

One line on the IP Box is worth repeating here, because in this corridor it is load-bearing twice over: the IP Box is the largest single line in a Cyprus product company's tax position — and the easiest one to forfeit through bookkeeping that was never set up for it. It is also the line that decides your Kazakhstan CFC effective rate, which is why the application opens as a conversation rather than as a form.

What happens when you get in touch

You do not need to have decided anything before you speak to us, and you do not need your paperwork in order.

1. The meeting. Fifteen minutes. You tell us what you own and when you want to move. We tell you which rules at home catch you, and what the Cyprus side costs.
2. We tell you what kind of case you have. If it is simple, we do all of it — company, books, residency, non-dom — at a fixed price. If it is not, we say so immediately and bring in the specialist it needs.
3. We start. The company is registered, your books open the same day, and you have one point of contact for the whole thing.

Questions Kazakhstan founders actually ask

Frequently asked

Is Kazakhstan's personal income tax still a flat 10%?

No. It stopped being flat on 31 December 2025. Article 363(1) of the 2026 Tax Code sets 10% on taxable income up to 8,500 MRP and 15% on everything above that. At the 2026 MRP of 4,325 tenge the 10% band runs to 36,762,500 tenge of taxable income in the calendar year. The flat-10% claim is still printed almost everywhere, including on pages dated 2026, and it is the single most repeated stale fact about Kazakhstan tax.

Does the Kazakhstan–Cyprus treaty keep a Cyprus company out of the CFC rules?

On the face of the statute, no — and this is the finding this guide leads with. Article 332(1)(1) excludes companies in treaty states only where the nominal profit tax rate there is more than 75% of Kazakhstan's 20% corporate rate. Seventy-five per cent of twenty is fifteen, and Cyprus has charged exactly 15% since 1 January 2026. Fifteen is not more than fifteen, so the carve-out does not reach Cyprus. Whether Cyprus appears on the Ministry's published list is a separate administrative question you should put in writing.

Does that mean my Cyprus company is automatically a Kazakhstan CFC?

No. Failing the treaty carve-out only means Cyprus is not excluded at the door. All three limbs of article 332(1) still have to be met at once, and the third one asks whether the effective rate is under 10% or the state is on Kazakhstan's low-tax list. Cyprus is not on the 2026 list approved by Order No. 492 of 12 September 2025. So it comes down to your own effective rate — a three-year arithmetic average of tax actually paid over accounting profit, which a Cyprus IP Box can pull below 10%.

Is there still a three-year holding exemption on Kazakhstan dividends?

No, and this repeal is the most consequential one for a founder. The old exemption for dividends on shares held more than three years was not carried into the 2026 Code. What survives with a three-year test is a capital-gains relief in article 337(2)(7)–(8), and it only covers shares or participation interests in Kazakhstan-resident issuers, excluding subsoil users. It will not shelter the sale of a Cyprus company, and it is not a dividend rule.

Does Kazakhstan charge an exit tax when a founder emigrates?

No. There is no deemed disposal on emigration, no departure charge and no exit return. We read the consolidated 2026 Code in full and there is no cessation event that triggers on leaving; residence is a status test under article 222 that simply stops being met. What follows you is filing exposure, not a charge — above all the annual declaration of income and property, which any stake in a foreign company triggers at any value.

If I leave Kazakhstan in July, when does my residency actually end?

Not on the day you fly. Article 222(2) counts 183 days across any consecutive twelve-month period ending in the tax period, so the window keeps sliding rather than resetting in January. The second route in — centre of vital interests under article 222(3) — is conjunctive: all three limbs have to be satisfied at once, which means breaking any single one breaks the test. In practice the limb you control is the Kazakhstan home available at any time for you or a close relative to occupy.

Can I split a Cyprus company with my brother to stay under 25%?

No, and this is the most common structuring mistake in the corridor. Article 332(3)(11) defines constructive ownership to aggregate a resident's holdings with those of close relatives, and article 332(3)(7) makes that list long: spouse, children including adopted, the spouse's children, grandchildren, the spouse's grandchildren, dependants and the spouse's dependants, parents and the spouse's parents, full and half siblings, and the spouse's full and half siblings. Ownership is measured at 31 December.

What actually happens to my Kazakhstan company when I move?

It stays Kazakhstan-resident by incorporation under article 223(1)(1) — moving the founder does not move the company. Winding it up is not a quiet exit either: liquidation reporting is due within three working days of approval of the interim liquidation balance sheet, and filing it is itself a statutory ground for a tax audit under article 75(2). The worst option is the drifting middle, where a Kazakhstan company is quietly run from Cyprus.

Does Sumly advise on Kazakhstan tax?

No. Sumly builds and runs the Cyprus side: formation, books from day zero, Cyprus VAT, VIES, provisional and corporate returns, payroll where it applies, and the tax residency and non-dom application. This guide quotes the Tax Code of the Republic of Kazakhstan and the currency law so you can see the shape of the decision, but how article 332 or article 222 lands on your facts is a question for a Kazakhstan adviser. Where a case needs one, we connect you with expert lawyers from our network.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Non-resident company formation — the route that applies outside the EU
• Cyprus non-dom status — the 17-year exemption in detail
• The Cyprus 60-day rule — day counting and the residency certificate
• The Cyprus IP Box — how qualifying income reaches an effective 3%
• What the 2026 Cyprus tax reform changed — the rate rise, the dividend cut and the abolitions
• How to register a company in Cyprus and what it costs

The calculator on this page uses headline rates, an assumed annual return and full distribution of profit, so it shows the shape of the difference rather than your own outcome. Kazakhstan figures are stated for 2026 under Tax Code No. 214-VIII, with tenge thresholds computed at the 2026 MRP and euro equivalents indicative only; Cyprus figures apply from tax year 2026. All Sumly prices exclude VAT, and government expenses on a formation are invoiced separately once your application is approved.