Kazakhstan Legal Forum 2026: CFA Auditors in Almaty

Nicolas Trikkis, Managing Director of CFA Auditors Ltd, attended the Kazakhstan Legal Forum 2026 at Rixos Almaty and remains available for private consultations on Cyprus holding, financing and tax structures for Kazakh groups.

Thank you, Almaty

The sixteenth Kazakhstan Legal Forum has concluded. Our thanks go to Lincoln Company and to the co-organisers — Sayat Zholshy & Partners, TKS Disputes, K&P Disputes, the British Kazakh Law Association, Artyushenko & Partners and Revera — for a forum of real quality, and for a welcome that was warm from the first handshake to the last. Kazakh hospitality is not something one reads about in a guidebook; it is something one is shown, and we are grateful for it.

The panels, and the private meetings that followed, were of considerable value: hearing Kazakh counsel and in-house teams describe how the new Tax Code is landing in practice is worth more than any amount of desk research. We return with our view confirmed and better founded — Cyprus is a serious and increasingly well-matched destination for Kazakh groups looking outward, used with genuine substance and on treaty terms.

About the forum

The Kazakhstan Legal Forum, held annually since 2010 and organised by Lincoln Company, is the country's principal gathering for in-house counsel, private practice lawyers, tax advisers and financial officers. The 2026 edition — the sixteenth — took place on 24 and 25 September at Rixos Almaty, and brought together practitioners from Kazakh corporate groups, banks and international firms.

For Kazakh groups holding assets abroad, raising finance internationally, or planning an eventual sale, the forum is one of the few occasions in the year where cross-border structuring can be discussed face to face with the advisers who would implement it.

Why CFA Auditors attended

CFA Auditors Ltd is a Larnaca firm of chartered accountants, established in 2010 and regulated through ACCA and ICPAC membership. The firm advises international groups on Cyprus company formation, accounting, statutory audit and tax planning, and works with Kazakh clients across real estate and construction, communications and technology, and financial services.

Both Cyprus and Kazakhstan rewrote their tax codes with effect from 1 January 2026. Structures designed under the previous rules on either side should be reviewed: several outcomes have moved, and not all in the same direction.

What we discussed in Almaty

• Cyprus holding structures — participation exemption on dividends with no minimum holding percentage or period, and exemption on gains from the disposal of shares and other titles.
• The Cyprus–Kazakhstan double tax treaty — a 5% ceiling on dividends where a company holds at least 10% of the payer directly, 10% on interest and royalties, and Cyprus-only taxing rights on most share disposals.
• The notional interest deduction — why equity deployed into Kazakhstan attracts a materially higher notional rate than the same structure funding western European activity.
• Substance — what Kazakh and other tax authorities actually test, and the evidence file that answers a beneficial ownership or principal purpose challenge.
• The controlled foreign company question — why Cyprus's 15% rate does not clear Kazakhstan's list threshold, and what that means for your effective rate analysis.
• Relocation for principals — the 60-day tax residency rule and non-domiciled status.

Cyprus at a glance for a Kazakh group

Forum details are those published by the organiser. CFA Auditors attended as a participant and is not an organiser of the event; the KLF and co-organiser marks shown in the photograph belong to their respective owners. See thelawyer.kz.