Estonian Company Run from Kazakhstan: Tax Rules

Many people living in Kazakhstan form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Kazakhstan. The Tax Code of Kazakhstan looks at where a company is managed: a legal entity created under foreign law whose place of effective management is in Kazakhstan is a resident of Kazakhstan, and a resident pays tax on income from sources in Kazakhstan and abroad. A Kazakh resident who owns 25 percent or more of a low-taxed foreign company can be caught by the controlled foreign company rules. And the Estonia–Kazakhstan tax treaty leaves a company resident in both countries to an agreement between the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Kazakh tax adviser before you form or buy the company. We read the Tax Code of the Republic of Kazakhstan of 18 July 2025 (No 214-VIII) in its Russian text on adilet.zan.kz, the official legal information system of Kazakhstan, and the Estonia–Kazakhstan tax treaty in Riigi Teataja, on 22 October 2026; the English wording of the Code below is our translation.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Kazakhstan: the company side

Resident. A legal entity is resident when it is created under the law of Kazakhstan, or created under the law of a foreign state and its place of effective management (the location of its actual management body) is in Kazakhstan (Tax Code, Article 223(1)).
Place of effective management. It is the place where the actual management body — the board of directors or a similar body — holds the meeting at which management and/or control is exercised and the decisions needed for the entity's business are taken (Article 223(2)).
What a resident pays on. A resident of Kazakhstan pays tax on income from sources in Kazakhstan and outside it (Article 221(1)).

An Estonian OÜ is a legal entity created under foreign law for this rule. If you live in Kazakhstan and the management board takes its decisions there, Kazakhstan can treat the company as a resident. Your Kazakh tax adviser answers that with the facts of your case.

In Kazakhstan: the owner side

Resident individual. An individual is resident when staying permanently in Kazakhstan — at least 183 calendar days in any consecutive twelve-month period ending in the tax period — or when the centre of vital interests is in Kazakhstan (Article 222(1)–(3)).
Controlled foreign company. A non-resident legal entity is a controlled foreign company when, on 31 December of the reporting period, 25 percent or more of its shares are held directly, indirectly or constructively by a Kazakh resident, or a resident controls it, and its effective profit tax rate is under 10 percent or it is registered in a state with preferential taxation (Article 332(1)).
Treaty countries. Excluded is an entity established in a state with which a tax treaty is in force, if that state's nominal profit tax rate is more than 75 percent of the Kazakh corporate income tax rate; the authorised body approves the list of these countries (Article 332(1)).

Whether Estonia is on that list, and how the profit of a controlled foreign company is then taxed in your hands, is a question for your Kazakh tax adviser.

The Estonia–Kazakhstan tax treaty

A company resident in both countries. The competent authorities shall endeavour to settle the question by mutual agreement; without agreement, the company is in each country deemed not to be a resident of the other country for the Convention (Convention signed in Astana on 1 March 1999, Article 4(3)).
Dividends. The country of the paying company may tax dividends at no more than 5 per cent of the gross amount if the beneficial owner is a company holding directly at least 25 per cent of the capital, and 15 per cent in all other cases (Article 10(2)).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

Whether the Multilateral Instrument changes these articles is a question for your Kazakh tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the management board meets and decides. That is the place of effective management under Article 223(2).
Who owns the company, and where they live. A Kazakh resident holding 25 percent or more brings in the controlled foreign company rules.
How you take money out. A dividend, a board fee and a salary fall under different articles of the treaty.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Kazakh tax returns and Kazakh tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

The two company forms side by side — founders, capital, share transfer and the corporate income tax: Estonian OÜ or Kazakh TOO.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Kazakh tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Kazakhstan if I run it from Kazakhstan?

It can be. The Tax Code of Kazakhstan counts a legal entity created under foreign law as resident when its place of effective management is in Kazakhstan — where its board of directors or similar body meets, exercises management and/or control and takes the decisions needed for its business (Article 223). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Kazakhstan tax treaty, the two tax authorities try to settle the residence of a company resident in both by mutual agreement (Article 4(3)). A Kazakh resident holding 25 percent or more of a low-taxed foreign company can be caught by the controlled foreign company rules (Article 332). Ask a Kazakh tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Kazakhstan: what is taxed where