AIFC registration in 2026: how to get 0% corporate tax and still have it a year later
In short:
In short: 0% corporate income tax is available only to licensed participants that meet the Substantial Presence rules. Fail them and you lose the relief and pay the standard 20%.
The AIFC is often sold as “English law and 0% corporate tax until 2066”. That is true, but it is not the whole story. Since 2022 the Centre has applied Substantial Presence rules, under which tax relief can be lost as quickly as it was gained. And in 2026 the regulator is checking compliance not on paper but against the facts — headcount, real expenditure, the number of days directors are physically present.
This article covers what AIFC registration actually gives you, how to go through it and, most importantly, how to organise the business so that the relief lasts for years rather than turning into an ordinary 20% corporate tax bill after the first inspection. The cost of getting it wrong here is not a penalty for a breach — it is losing the preferences the company came to the AIFC for.
What the AIFC is, and who it actually suits
The Astana International Financial Centre (AIFC) is a special jurisdiction established on the EXPO-2017 site in 2018. It now has more than 5,170 registered companies from over 80 countries and has attracted upwards of USD 16.9 billion in investment.
Three things set the AIFC apart from an ordinary Kazakh company. The legal environment runs on English common law, with its own court (the AIFC Court) and arbitration centre (the IAC), which matters for international contracts. The tax regime gives 0% corporate income tax until 2066 on qualifying activities, 0% VAT on financial and intermediary services, and no tax on dividends or capital gains. And the regulatory environment has its own regulator, the AFSA, built for financial markets.
Who it suits
Financial companies, fintech projects, professional services with international clients, and holding structures with export revenue.
Who it does not suit
Local businesses serving Kazakh customers, trading operations with no international element, and companies with no genuine operations.
Tax relief: what the AIFC really gives
The key distinction, rarely spelled out: AIFC relief is not universal. The full package is available only to licensed participants carrying on market and regulated activities.
For those participants: 0% corporate income tax until 2066 on income from qualifying activities, VAT exemption on the relevant transactions, and zero rates on dividends and capital gains within the jurisdiction.
For non-licensed participants the picture differs: relief remains only on dividends and gains from shares and participation interests in an AIFC company, and other taxes are paid on ordinary terms.
An important detail: AIFC participant relief does not automatically extend to payments made to non-residents. Payments to foreign companies for licences, services and royalties are taxed under the general provisions of the Tax Code. That is an area you must model when structuring.
Substantial Presence: the rule that matters most
Since 2022 the AIFC has applied Substantial Presence rules. They were introduced in response to OECD criticism under BEPS Action 5. The AIFC does not want to appear on any list of tax havens, so the rules are strict.
- Registered address: within the AIFC. Licensed activities require physical office space.
- Employees: at least one employee who is a Kazakh resident.
- Directors: physically present in the country for at least 30 days a year.
- Income: at least 50% of revenue must come from qualifying activities.
What happens if you fail: the regulator reclassifies the company as a non-resident of the AIFC and applies standard Kazakh tax rates — the 20% corporate income tax instead of zero. A company registered for the relief ends up on ordinary taxation after the first inspection.
Company types and how registration works
The procedure itself is relatively quick — three to fourteen business days with the documents properly prepared. Several legal forms are available: Private Company (the equivalent of an LLP), Public Company, Limited Partnership, and branches and representative offices of foreign companies.
Checklist before you register
- Do your activities qualify under the AIFC classification?
- Are you prepared to meet the Substantial Presence requirements?
- Will at least 50% of income come from qualifying activities?
- Have you modelled the tax on payments to non-residents separately from AIFC participant relief?
- Do you have the management capacity to keep up the required reporting?
Conclusion
The AIFC is a powerful instrument for financial businesses, fintech, and export and holding structures. But it is not an offshore for everyone — it is a jurisdiction with a hard filter at the entrance and continuous oversight afterwards.
The lawyers at Osmar Group handle AIFC registration from choosing the form and preparing the documents through to structuring the operating model around the Substantial Presence requirements — so that the relief is not merely obtained but kept.
Frequently asked questions
What tax relief does AIFC registration give?
For licensed participants: 0% corporate income tax until 2066, VAT exemption on the relevant transactions, and no tax on dividends or capital gains within the jurisdiction. For non-licensed participants, relief on dividends and capital gains only.
How long does registration take?
With the documents properly prepared, three to fourteen business days. Obtaining an AFSA licence for regulated activities is a separate procedure with its own timetable.
Can AIFC tax relief be lost after registration?
Yes. Failing the Substantial Presence rules leads to the company being reclassified as a non-resident of the AIFC and taxed at the standard 20%.
Who does the AIFC not suit?
Local businesses with Kazakh customers and no international element, trading operations, and companies with no genuine operations — Substantial Presence is unachievable for them, so the relief is out of reach.