Part II. The Astana International Financial Centre: Licensing And Tax Incentives

Following the publication of Part 1, which outlined the AIFC's governance model, legal framework and company registration processes, this second part continues the discussion by focusing on two core aspects of operating within the Centre: the licensing of financial and non-financial services, and the tax incentives and preferences of the AIFC.

V. Licensing of Financial and Non-Financial Services

1. General Overview
The Registrar categorizes all AIFC participants into two broad groups: non-regulated (license not required) and regulated (license required). If a company plans to conduct financial services or provide professional services within the AIFC, it must obtain authorization and a license from AFSA – the AIFC's independent regulator. Licensing applies to a wide range of activities, including:

• Regulated Financial Services: banking, insurance, reinsurance, investment management, operation of investment firms and funds, brokerage and dealing, fiduciary management of securities, operation of capital market trading venues, digital asset activities, and more. For instance, a Banking License is required for banking activities; an Investment Firm License for brokerage/dealer and asset management activities; an Insurance License for insurance providers; and a FinTech License for crypto platforms, electronic money institutions, etc ²⁴;
• Non-Financial (Ancillary) Services: These include professional services provided to AIFC participants such as audit, accounting, legal advice, consulting, and others. This requires obtaining the status of an Approved Ancillary Service Provider and relevant approval from AFSA. For example, a law or consulting firm wishing to serve clients in the AIFC must obtain a license for legal or consulting services within the Centre ²⁵;
• Market Activities: These refer to the operation of key financial infrastructure within the AIFC, such as exchanges, clearing houses, and crowdfunding platforms. Entities engaging in these activities must obtain specific authorization from AFSA. Examples include operating a trading facility (e.g. AIX), a clearing house, or a digital asset platform. These activities are critical for enabling capital markets and investment services within the AIFC framework ²⁶.

2. Types of Licenses and Requirements
Each license type comes with its own set of requirements. In general, to successfully obtain a license, a company must demonstrate to the regulator that it:

1. is financially sound, with adequate capital and liquidity;
2. has established systems of internal control and compliance (e.g. AML procedures, risk management, client protection);
3. is managed by qualified executives and employees of good repute.

AFSA requires submission of a business plan, financial model, internal policies and procedures, information on beneficiaries and management, and confirmation of minimum capital compliance.

The higher the risk or scale of the activity, the greater the capital requirement (banking institutions may require millions of USD in capital depending on the scope).

Authorization with the Registrar involves several stages:

• Pre-application consultations (optional);
• Submission of a comprehensive license application and documentation package;
• Conversation with the regulator and fulfillment of conditions before license issuance.

Once the full application is received, AFSA assigns a case officer within ~3–5 business days. Initial assessment takes ~10 business days, during which AFSA may request clarifications. The full review period averages 2–3 months for financial activities and ~1 month for ancillary services, provided the documentation is complete.

If requirements are met, AFSA issues an In-Principal Approval (IPA). A temporary approval may be granted at this stage to allow registration finalization or capital placement. The IPA letter specifies any outstanding conditions (typically to be fulfilled within 1–3 months) such as capital top-up, staff hiring, IT system acquisition, office lease, etc. Upon completion and final inspection, AFSA grants the license and lists the company in the register of Authorised Firms. The total licensing process usually takes 2–4 months (including preparation time).

3. Fees and Licensing Costs
License application review is subject to fixed AFSA fees, which vary by license type and activity. For financial licenses, this can amount to several thousand USD. Exact fees for regulated activities go as follows ²⁷:

If a company applies to conduct regulated activities involving digital assets (like custody or advising), it must pay an additional $2,000 application fee to the Registrar. This extra fee does not apply if the company is only applying to operate a Digital Asset Trading Facility, which already has a higher fee ²⁸.

The application fees for market activities are the following ²⁹:

Note: The additional $5,000 applies if the Operator intends to:

• Clear or trade Investment Tokens, and
• Have Direct Access Members.

The application fees for Ancillary Services are equal to one another and amounts to USD 2,000 ³⁰. This includes licenses for:

• Providing Legal Services
• Providing Audit Services
• Providing Accountancy Services
• Providing Consulting Services

Finally, there are also application fees for recognition as a Recognised Non-AIFC Market Institution, Recognised Non-AIFC Member and Foreign Fund Manager. The fees are ³¹:

VI. Tax incentives and preferences of the AIFC

A critical component of the AIFC's attractiveness is the suite of tax advantages and migration incentives offered to AIFC participants and their foreign staff. Kazakhstan has granted the AIFC an exceptionally favorable tax regime – in some cases a 50-year tax holiday – to stimulate long-term investment in the Centre. Additionally, streamlined visa and work permit rules make it easy for international professionals to live and work in Astana for AIFC-related business. The AIFC's tax regime is governed by Article 6 of the Constitutional Statute, which provides broad exemptions from national taxes for activities in the Centre.

For example, AIFC participants are exempt from corporate income tax on most income related to financial services operations conducted in the AIFC, until January 1, 2066 ³². This exemption covers income from core financial activities such as banking (Islamic and conventional), insurance and reinsurance, securities brokerage and trading, asset management, investment advising, underwriting, and other financial services as defined by joint AIFC government acts ³³. In effect, banks, insurers, asset managers, and brokers in the AIFC pay 0% corporate tax on their AIFC-sourced income for 50 years. The AIFC Authority and other AIFC bodies themselves are also exempt from CIT through 2066 ³⁴.

To attract skilled foreign talent, the law grants a full individual income tax exemption to foreign employees of AIFC participants and bodies on income they earn from their AIFC work (until 2066) ³⁵. In other words, expatriates working for an AIFC-registered company pay 0% tax on their salaries and bonuses. This is a significant incentive, effectively allowing AIFC firms to offer tax-free compensation packages, which is especially competitive regionally. Local Kazakhstani employees working in the AIFC do pay normal income tax, but the presence of the expat exemption helps AIFC entities bring in foreign experts easily.

Investors are enticed with zero taxes on investment gains. Both individuals and legal entities are exempt from taxation on capital gains derived from the sale of securities listed on the AIFC's stock exchange (AIX), as well as from the sale of participatory interests in companies registered within the AIFC ³². According to the same presidential decree, dividends and interest earned from AIX-listed securities are also tax-exempt. Furthermore, dividends paid by an AIFC company to its shareholders are tax-free. These measures significantly enhance the appeal of using AIX for IPOs or bond listings, as investors can realize returns without tax leakage. The exemptions extend to income from outside Kazakhstan for "investment residents" of the AIFC – a status high-net-worth individuals can obtain, subject to a fee, to become tax resident in Kazakhstan and enjoy exemption on their foreign-sourced income ⁹. This essentially functions as an "investment tax residency program", positioning Kazakhstan competitively among jurisdictions offering favorable residency tax schemes.

Financial services rendered by AIFC participants are exempt from Kazakhstan's value-added tax (VAT) ³⁶. On top of that, AIFC companies and the AIFC Authority are exempt from property tax and land tax on real estate in the AIFC territory. These relieve operational cost burdens. The law also clarifies that certain transfers (like budgetary funds granted to the AIFC Authority) are not treated as taxable turnover for VAT ⁹.

Cumulatively, these incentives amount to one of the most generous tax regimes offered by any financial centre globally. For 50 years – effectively up to mid-century – AIFC participants enjoy a near-tax-free environment, which is a deliberate move to attract long-term projects and make Astana a regional magnet for financial institutions. The government's commitment to maintain this regime through 2066 provides certainty to investors that the rules will not suddenly change, a critical factor for those making location decisions.

In addition to tax incentives, the AIFC provides a favorable migration regime for foreign professionals. Citizens of OECD countries and key partner states (such as the UAE, Malaysia, Singapore, and Monaco) can enter Kazakhstan visa-free for up to 30 days for AIFC-related purposes. Foreign nationals employed by AIFC participants or designated as "investment residents" – along with their family members – are eligible for multi-entry visas valid for up to five years, which can be extended without leaving Kazakhstan ³⁷. These visas are processed through the AIFC Expat Centre, ensuring efficient and centralized procedures.

Importantly, AIFC participants are exempt from Kazakhstan's general work permit quota. Foreign employees may work without a separate permit, provided their qualifications are documented and retained by the employer. The AIFC Authority maintains coordination with national migration bodies.

The Expat Centre also assists with relocation, housing, schooling, and local integration. All procedures are in English ³⁸.

VII. Conclusion

The AIFC represents Kazakhstan's strategic shift towards economic diversification and its integration into the global financial system. Established in response to the oil price collapse, the AIFC offers a distinctive common-law legal framework, independent dispute resolution mechanisms, and an investor-friendly business environment, making it an attractive hub for international business. Its streamlined registration processes, comprehensive licensing regimes, and world-class tax and migration incentives further enhance its appeal to foreign investors, financial institutions, and professionals.

By combining regulatory clarity with long-term fiscal incentives, the AIFC is well-positioned to become a competitive regional financial center. Its commitment to providing a transparent, predictable, and stable environment for businesses underscores Kazakhstan's broader goals of economic resilience and global financial integration. Through its innovative legal framework and institutional support, the AIFC not only contributes to Kazakhstan's economic transformation but also offers a model for other emerging markets seeking to attract global capital and expertise.

Footnotes

9 Astana International Financial Center (2025) Astana International Financial Centre, AIFC: main website. Available at: https://aifc.kz/, accessed on 25.10.2025.

24 Schedule 1 of AIFC General rules – Regulated activities.

25 Schedule 2 of AIFC General rules – Ancillary services.

26 Schedule 4 of AIFC General rules – Market activities.

27 Schedule 1(1.1) of AIFC fees rules – Application Fees Payable to The AFSA for Regulated Activities.

28 Schedule 1(1.1-1) of AIFC fees rules – Application Fees Payable to The AFSA for Regulated Activities.

29 Schedule 2(1.1) of AIFC fees rules – Application Fees Payable to The AFSA for Market Activities.

30 Schedule 3(1.1) of AIFC fees rules – Application Fees Payable to The AFSA for Ancillary Services.

31 Schedule 4(1.1) of AIFC fees rules – Application Fees Payable to AFSA For Recognised Non-AIFC Market. Institution, Recognised Non-AIFC Members and Foreign Fund Managers.

32 Article 6(2) of Decree of the President of the Republic of Kazakhstan No. 160.

33 Article 6(3) Decree of the President of the Republic of Kazakhstan No. 160.

34 Article 6(4)(6) Decree of the President of the Republic of Kazakhstan No. 160.

35 Article 6(7) Decree of the President of the Republic of Kazakhstan No. 160.

36 Article 6(8) Decree of the President of the Republic of Kazakhstan No. 160.

37 AIFC (2024) Investment tax residency programme, AIFC. Available at: https://aifc.kz/faq/investment-tax-residency-programme/; Article 7(2-1 (2) Decree of the President of the Republic of Kazakhstan No. 160, accessed on: 5.10.2025.

38 AIFC (2025c) AIFC expat centre – visas, adaptation, and support in Kazakhstan, AIFC. Available at: https://aifc.kz/expat-centre/?ysclid=mdnldqas29763728841, accessed on: 5.10.2025.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.