Tax Messenger
Currency regulation in Kazakhstan: transactions lacking apparent economic substance
05.05.2026
In April 2026, amendments to the Rules for Currency Transactions in the Republic of Kazakhstan[1] entered into force, introducing, inter alia, the concept of transactions lacking apparent economic substance.
KEY PROVISIONS
- Transactions lacking apparent economic substance include financial loans provided by residents to non-residents (nonaffiliates) when the relevant contract (including as amended) does not provide for any interest.
- Such transactions may be carried out subject to the resident approving the authorized bank to disclose information on the transaction to currency control authorities and law enforcement agencies.
- Such consent may be given in any form.
AUTHORS
Irina Bykhovskaya
B1 Partner
Tax, Law and Business Support
Contact
Amangeldy Mussayev
BeOne Kazakhstan Partner
Tax, Law and Business Support
Contact
Show references
-
[1] Approved by Resolution No. 40 of the Management Board of the National Bank of the Republic of Kazakhstan dated 30 March 2019
OTHER PUBLICATIONS
View all
Transfer pricing in UAE: declaration period and new FTA explanations
With the 30 September 2026 deadline for filing the 2025 corporate tax return approaching, companies should focus on ensuring the accurate disclosure of transactions with Related Parties and Connected Persons in the TP Disclosure Form.
10.06.2026
UMMC: revised time limits for decisions to initiate transfer pricing audits
On 29 April 2026, the Moscow District Arbitration Court issued a ruling in the Ural Mining and Metallurgical Company case No. А40-72524/2025 regarding the time limits for ordering transfer pricing audits of tax calculations and payments in related party transactions. Both at first instance and on appeal, the case was ruled in favor of the taxpayer, but these rulings were quashed by the court of cassation.
08.05.2026
Currency regulation in Kazakhstan: transactions lacking apparent economic substance
In April 2026, amendments to the Rules for Currency Transactions in the Republic of Kazakhstan entered into force, introducing, inter alia, the concept of transactions lacking apparent economic substance.
05.05.2026
Draft procedure for payment of technology fee published
The Russian Ministry of Industry and Trade has published a draft Government Decree establishing the procedure and deadlines for the payment of a technology fee. The Fee is scheduled to come into force on 1 September 2026 and, as previously reported, it will apply to electronic devices that are manufactured in or imported into Russia. The Fee will be payable by manufacturers and importers of such devices – both legal entities and individual entrepreneurs.
23.03.2026
Regulatory and tax control shifts in the IT sector: areas to focus on in early 2026
The end of 2025 was marked by numerous changes in IT regulation. When considered as a systemic whole rather than individually, they indicate several trends that should be taken into account when assessing tax risks and opportunities for software and database developers – including members of corporate groups – and their clients.
16.01.2026
Uzbekistan tax alert – 2026 legislative changes
In November 2025, the Ministry of Economy and Finance of the Republic of Uzbekistan released a draft budget message outlining several proposed tax policy changes effective from 2026. The implementation of the proposed measures is contingent upon the adoption of the corresponding amendments to the tax code of the Republic of Uzbekistan in December 2025.
16.12.2025
Bill amending the Tax Code passes the second reading in the State Duma
On 18 November, the Russian State Duma adopted in the second reading Federal Bill No. 1026190-8 “On Amendments to Parts One and Two of the Tax Code of the Russian Federation and Certain Legislative Acts of the Russian Federation”, which includes amendments proposed by the Government for the second reading of the Bill in the State Duma. After its third reading on 20 November, the Bill will be submitted to the Federation Council and then to the Russian President.
19.11.2025