Legal aspects of taxing foreign digital companies in the Republic of Kazakhstan

Abstract

The article examines the legal regulation of taxation of foreign digital companies in the Republic of Kazakhstan in the context of the digital economy. The relevance of the study is determined by the rapid growth of cross-border digital services and the need to adapt national tax legislation to new business models that operate without a physical presence in the state where services are consumed. The purpose of the research is to analyze Kazakhstan’s current legislation governing the taxation of foreign digital companies, identify existing regulatory challenges, and develop proposals for improvement based on international experience. The study employs comparative legal, systemic, and formal-logical methods, as well as an analysis of international approaches to digital taxation.

The scientific novelty of the research lies in the comprehensive assessment of Kazakhstan’s digital taxation framework in light of the new Tax Code of 2025 and international initiatives such as BEPS, Pillar One, and Pillar Two. The findings reveal challenges related to the identification of non-resident taxpayers, transparency of digital transactions, and cross-border exchange of tax information. The study concludes that Kazakhstan should establish a legal definition of digital services, improve tax administration, and harmonize national legislation with international standards. The findings may contribute to the development of tax policy and the further improvement of Kazakhstan’s digital taxation framework.