AIFC vs. Kazakhstan LLP in 2026: Which Structure Actually Fits Your Business

• 0% CIT on revenue (non-resident qualifying clients).
• 0% PIT on AIFC-employed KZ-based engineers (~15 people).
• English common law governs contracts; familiar to EU clients.
• No FX controls — EUR revenue flows freely.

• 10-20% CIT; 10% PIT on staff.
• Kazakh civil law — requires additional side-letter mechanics for EU clients.

• Pass-through dividend treatment for qualifying holdings.
• Common law for shareholder agreements and intellectual property licensing.
• Favourable exit mechanics (English law share purchase agreements).
• AIFC IP Box regime available.

• Workable but Civil Code rigidities around share transfers, pre-emption rights.
• Less familiar to foreign M&A counterparties.

• AFSA-regulated fund vehicle.
• AIFC Collective Investment Scheme rules — international investor comfort.
• 0% CIT for the fund and the manager.
• GP/LP structures available.

• Kazakh investment fund regulation applies — narrower, less flexible.
• LP investors from outside CIS — significant legal explanation overhead.

• SNR regime: 10% CIT on revenue (or similar depending on sub-regime).
• Full national banking access — Kaspi Pay integration, Halyk pos terminals.
• Standard KZ tax returns — no AFSA overhead.
• Bank processes rubles and yuan easily.

• Not eligible for 0% CIT — this is a trading activity serving Kazakh residents.
• Taxed at standard rates anyway.
• AIFC office rent 3-5× standard Almaty commercial rent.
• AFSA substance obligations, even as a non-regulated participant.

• Participates in Kazakh public tenders (requires local supplier status).
• Standard invoicing, Russian/Kazakh.
• Integrates with Kazakh chamber of commerce and ОЭЗ programmes.

• Cannot compete on local tenders on the same footing.
• Local content certification (СТ-KZ) is tied to national LLPs.

• 10% CIT; 10% PIT on staff.
• Fast setup, simple reporting.
• No substance test.
• Staff on KZ IIN, easy to hire locally.

• 0% CIT, 0% PIT.
• Setup $3,000-5,000; higher annual compliance cost ~$5,000-10,000/year.
• Substance requirement — real office in AIFC Astana.
• Fewer banks, but international-friendly.

• If staff is already in Astana / happy to be: AIFC.
• If staff distributed across Kazakhstan: LLP.

1. Are clients mostly non-residents? → AIFC leans yes; LLP leans no.
2. Is the activity financial / IT / IP / holding? → AIFC-eligible.
3. Is the activity physical trade or service to KZ market? → LLP.
4. Does the business need to pitch to EU/US funds or M&A counterparties? → AIFC's English-law story matters.
5. Will you fight tax at margins or hate state forms in Russian? → AIFC.
6. Will you outgrow SNR within 12 months? → AIFC-eligible activity becomes more compelling.
7. Do you need KZ state tenders access? → LLP.

• Compare the two structures for your specific business model on a spreadsheet: tax, compliance, exit mechanics, substance cost.
• Map which AFSA / non-AFSA AIFC status fits (Ancillary Services vs Authorised Firm).
• Set up the chosen structure end-to-end — registration, banking, substance, tax regime choice.
• Support ongoing compliance — both AIFC and national.

Is AIFC's 0% CIT unconditional?

No. The 0% CIT applies to 'qualifying activities' listed in the AIFC Acts — primarily financial services, capital markets activities, asset management, Islamic finance, reinsurance, IT/fintech services provided by AIFC participants to AIFC participants or to non-residents. Provision of general services to the Kazakh national market is taxed at standard rates. Always review the activity list before assuming tax exemption applies.

Can an AIFC company have non-resident clients only?

Yes. AIFC does not require a local client base. Many AIFC companies are set up as holdings, SPVs, or regional hubs serving EU/US/Asia markets. Revenue from non-residents is generally qualifying for CIT purposes (subject to the activity test).

Does an AIFC company need a physical office in the AIFC?

Yes — a registered office at the AIFC is a licensing requirement. AFSA (AIFC financial regulator) checks for substance: real directors, real operations, meeting rooms, staff. Pure shell setups don't pass substance review. Substance requirements are scaled to activity — a family office may need less than a brokerage.

What currency controls apply to AIFC companies?

AIFC participants are exempt from Kazakhstan's currency control rules — free FX transactions, no mandatory conversion, no contract registration with the bank for FX operations. This is one of AIFC's strongest practical advantages. Note: it applies to the AIFC participant itself, not its counterparties.

Can I convert an LLP into an AIFC company later?

Not directly. You can set up a new AIFC company and transfer the business, assets, or intellectual property into it — this is a restructuring project with tax and contractual implications. Plan the jurisdiction at the outset if AIFC is likely.

What is AFSA?

AFSA — AIFC Financial Services Authority. It's the AIFC's regulator. All licensed financial activities in the AIFC require AFSA authorization. AFSA's standards are modeled on international best practice (DFSA/FCA-adjacent). For non-financial AIFC companies (e.g. holdings), AFSA involvement is minimal; for regulated activities (brokerage, fund management, banking), AFSA is the main gatekeeper.

How does staff taxation differ?

For AIFC employees of AIFC participants, employment income from the AIFC employer is exempt from personal income tax until 2066 — on Kazakhstan-source income in scope. For LLP employees — standard 10% PIT. This is relevant for senior hires: a $200k expat package in the AIFC is materially more tax-efficient.

• AIFC setup
• LLP registration