A Cyprus platform for Kazakh corporate and financial groups
CFA Auditors provides an integrated Cyprus service line — company formation, accounting, statutory audit and tax planning — to corporate and financial groups in Kazakhstan. Our Managing Director will attend the Almaty Legal Forum and is available for private consultations.
An integrated Cyprus service line
Company formation, accounting, audit and tax planning are provided under a single engagement, so that a Kazakh group maintains one professional relationship from incorporation onward.
Company Formation
Incorporation of companies, partnerships and trusts in Cyprus and other jurisdictions, branch registration and redomiciliation, with beneficial ownership and CRS reporting addressed from the outset.
Accounting
Bookkeeping, management accounts and statutory financial statements prepared under IFRS, maintaining the Cyprus entity's records in an audit-ready condition throughout the year.
Audit & Assurance
Independent statutory audit conducted by ICPAC-licensed auditors, scoped to the group's structure and reporting timetable.
Tax Planning
Corporate structuring, international planning across the Cyprus treaty network, transfer pricing and tax rulings, together with relocation planning for the individuals behind the group.
Nicolas Trikkis
Managing Director of CFA Auditors, attending the Almaty Legal Forum in person on 24–25 September and available for private consultations from 23 September.
Nicolas Trikkis serves as Managing Director of CFA Auditors Ltd, holding overall responsibility for the firm's engagements — from initial incorporation through to the continuing administration of established group structures. He will attend the Almaty Legal Forum in person, and prospective clients are invited to discuss their requirements with him directly.
Under his direction the firm maintains a practice governed by ACCA and ICPAC membership and staffed by graduates of internationally recognised institutions. Its professional standards — excellence, commitment, teamwork, leadership and a personal approach to client service — inform its work across tax compliance, statutory audit and company formation, with particular experience in real estate and construction, communications and technology, and financial services: the sectors accounting for the majority of Kazakh outbound investment into Cyprus.
Cyprus holding and financing structures for Kazakh groups
The considerations that lead Kazakh groups expanding abroad, raising finance, or holding assets outside Kazakhstan to establish in Cyprus.
Company law derived from English common law, full access to the European Union and the eurozone, and a tax system accommodating holding and financing activity establish Cyprus as a principal jurisdiction for structuring outbound Kazakh investment.
- Corporate income tax of 15% (2026), which remains among the lower rates within the European Union
- Participation exemption: dividends and gains arising from qualifying shareholdings are generally exempt from Cyprus taxation
- No Cyprus withholding tax on dividends, interest or royalties paid to non-resident shareholders
- IP box regime, providing an effective tax rate as low as 2.5% on qualifying intellectual property income
- Notional interest deduction, which shelters a portion of the return on new equity introduced into a Cyprus company
The double tax treaty between Cyprus and Kazakhstan establishes favourable capped withholding rates and confers exclusive taxing rights on Cyprus residents in respect of most share disposals.
| Flow | Treaty rate |
|---|---|
| Dividends — holding of 10% or more | 5% |
| Dividends — other holdings | 15% |
| Interest | 10% |
| Royalties | 10% |
| Capital gains on disposal of shares | Cyprus only† |
† Save where more than 50% of the value of the shares derives from immovable property situated in Kazakhstan. Since 2021 the treaty has also incorporated a principal purpose test: benefits are available where the structure reflects genuine substance and commercial purpose — see the substance briefing below.
Dividends pass from the Kazakh operating company to the Cyprus holding company at the treaty rate, and onward to the ultimate owners without further Cyprus withholding tax. Where the owners themselves relocate to Cyprus under the non-domiciled regime, such dividends may be received free of Special Defence Contribution — see the relocation guide below.
A Cyprus company may also serve as the group's financing vehicle, advancing loans to operating subsidiaries at arm's-length rates that attract the 10% treaty rate on repatriation, while the notional interest deduction reduces the effective Cyprus tax cost of the equity supporting the loan.
Cyprus substance requirements
Treaty benefits and non-domiciled planning alike depend upon a Cyprus company that is genuinely managed and operated within the jurisdiction.
Demonstrable substance supports Cyprus tax residency status, prevents the creation of an unintended taxable presence in another jurisdiction, defends the structure against transfer pricing and beneficial ownership challenges, satisfies anti-avoidance and anti-abuse provisions such as the treaty's principal purpose test, and enables the group to exchange information transparently under CRS and automatic exchange of information rules.
Management and control
A board comprising a majority of Cyprus residents, with meetings convened and minuted in Cyprus and strategic decisions genuinely taken there.
Physical presence
A registered and operating office together with appropriately qualified local personnel, proportionate to the company's activity.
Adequate expenditure
Operating costs commensurate with the company's activity and with the assets it holds or finances.
Banking arrangements
An active Cyprus bank account, with the banking relationship genuinely administered from Cyprus.
A diagnostic review identifies substance risk within the existing structure and recommends the corrective realignment of functions and risk between Cyprus and Kazakhstan. The firm then establishes the physical operation — office premises, recruitment, employment contracts and work permits — together with the surrounding governance framework, and thereafter maintains the accounting, tax and audit coordination so that substance evidence remains current rather than being established at incorporation alone.
Tax relocation guide for individuals
Prepared for the principals of Kazakh groups: the requirements for establishing Cyprus tax residency, and the treatment available under non-domiciled status.
An individual qualifies as a Cyprus tax resident under the 60-day rule upon satisfying all four conditions within a calendar year:
- Physical presence in Cyprus of at least 60 days
- No tax residency in any other single country exceeding 183 days in that year
- The carrying on of business, employment or a directorship in a Cyprus tax-resident company — frequently the same company at the centre of the group structure
- The maintenance of a permanent residence in Cyprus, whether owned or rented
With effect from 1 January 2026, applicants are no longer required to demonstrate separately that they are not tax resident elsewhere, which simplifies the test.
Non-domiciled status is available to any individual not born in Cyprus who has not been a Cyprus tax resident for at least 17 of the preceding 20 years. It confers exemption from Special Defence Contribution, which remains payable by domiciled residents:
| Dividends (domiciled residents pay 17%) | 0% |
| Passive interest (domiciled residents pay 30%) | 0% |
| Rental income, on 75% of gross rent (domiciled residents pay 3%) | 0% |
| Wealth, gift and inheritance tax | Not levied in Cyprus |
Register as a Cyprus tax resident with the Tax Department and obtain a Tax Identification Code.
Secure a residential address in Cyprus, whether owned or rented.
Satisfy the 60-day physical presence condition and the no-other-residency condition.
Establish the qualifying business, employment or directorship connection in Cyprus.
Apply for non-domiciled certification to confirm the Special Defence Contribution exemptions.
Consultations with Nicolas Trikkis at Rixos Almaty
Mr Trikkis will attend the Forum at Rixos Almaty on 24–25 September and is available for private consultations throughout. He arrives on 23 September, and meetings on that day may be arranged separately at a venue to be confirmed. Appointments may be booked in advance to review your group's structure and to receive a tailored proposal.
A platform for CFA Auditors' special projects
Cyprus Tax Gateway is published by CFA Auditors Ltd and is dedicated to the firm's special projects: focused initiatives prepared for a particular market, delegation or professional event, and presented separately from the firm's general practice.
The present project addresses corporate and financial groups in Kazakhstan and accompanies the firm's attendance at the Almaty Legal Forum. It brings together the firm's service package, three technical briefings on Cyprus structures, and the arrangements for meeting the firm in Almaty.
CFA Auditors Ltd
A Larnaca practice of chartered accountants advising corporate and private clients internationally.
CFA Auditors Ltd is a firm of chartered accountants providing audit and assurance, taxation, accounting and business consultancy services to clients internationally. The practice was established to support organisations and individuals seeking considered professional guidance for their businesses, and it applies the same standard of attention across engagements of every size.
Its personnel hold membership of ACCA and ICPAC. The firm's approach rests on a personal relationship with each client, timely response to reporting deadlines, and equal treatment of clients irrespective of scale.
Visit cfa-auditors.com