Kazakhstan is not a country without its own low-tax options, which makes it the one guide in this cluster where Georgia has to compete against a genuine domestic rival rather than a high-tax status quo. Astana Hub offers 0% corporate tax to qualifying IT companies with no local office requirement, and the Astana International Financial Centre runs its own decades-long tax holiday for participants. Both are real alternatives worth ruling out before assuming Georgia is the obvious answer. This guide works through what Kazakhstan's newly restructured 2026 tax code actually charges a self-employed individual, whether Kazakh CFC rules reach a Georgian entity at all - and they are drafted more aggressively than most - and what the currency reporting rules mean once money starts moving between the two countries.
What a Kazakh freelancer actually pays, here and there
Kazakhstan rewrote its tax code for 2026, and the individual entrepreneur regime most solo freelancers use looks materially different from what it did a year earlier. Take a Kazakh IT freelancer invoicing 20,000,000 KZT a year, roughly 42,500 USD at current rates. Under the simplified regime, individual income tax runs at 10% on income below 8,500 times the monthly calculation index (about 36.8 million KZT for 2026), with a 6% social tax layered on top of the same base. On top of that, personal mandatory contributions apply: 10% pension, 5% social contributions capped at seven times the minimum wage, and a fixed health contribution of roughly 5,950 KZT a month.
Add it up and the honest all-in figure lands close to 28% of turnover - a real number worth knowing before assuming the Kazakh side is cheap simply because the country markets itself as tax-competitive.
| Kazakhstan (simplified IE regime, 2026) | Georgia (Small Business Status) | |
|---|---|---|
| Turnover | 20,000,000 KZT (~42,500 USD) | Same |
| Individual income tax (10%) + social tax (6%) | ~3,200,000 KZT | ~200,000 KZT-equivalent (1%) |
| Mandatory pension, social and health contributions | ~2,428,000 KZT | None required by the status itself |
| Total, all-in | ~5,628,000 KZT (~28%) | ~200,000 KZT-equivalent (~1%) |
Kazakhstan runs its own genuinely competitive domestic alternative for anyone operating an actual IT company rather than freelancing solo. Astana Hub grants 0% corporate tax and reduced individual income tax to qualifying technology businesses earning at least 90% of revenue from software, AI, cybersecurity, fintech and a defined list of adjacent categories, with no requirement for a local office or Kazakhstan-based staff. The Astana International Financial Centre runs a parallel, separately structured tax holiday running to 2066 for its own participants, mostly financial and professional services. Neither replaces Georgia's 1% for a solo freelancer who does not meet Astana Hub's activity test, but a genuine software company reading this guide should rule Astana Hub out specifically before assuming a foreign registration is the better move.
Does Georgia's 1% actually apply to your income in the first place
None of the Kazakh math above matters until the 1% genuinely applies, which is a Georgian-side question first. Small Business Status taxes Georgian-source income, and for services that generally means work physically performed in Georgia or income earned while you are actually a Georgian tax resident - not work invoiced through a Georgian registration while sitting in Almaty or Astana. We cover the mechanics in full in Georgia's 1% tax and the source test specifically in Georgian-source income rules, and neither test changes for a Kazakh national. Consulting, legal, medical and licensed activities are excluded from the regime regardless of nationality.
What Kazakhstan does when you leave
Kazakh tax residency, set out in Article 217 of the Tax Code and summarised by PwC, is tested by 183 days or more of physical presence in a rolling 12-month period, or by a centre of vital interests located in Kazakhstan even without meeting the day count - defined as holding Kazakh citizenship or a residence permit, a spouse or close relatives resident in Kazakhstan, and property available for the family's use. Genuinely breaking residency means closing all three strands of that test, not just relocating physically.
The technical point that matters most here is Kazakhstan's CFC regime, drafted more broadly than the EU-style rules elsewhere in this cluster. A controlled foreign entity is a foreign person - explicitly including a company or another form of unincorporated entrepreneurship - held substantially by a Kazakh resident, where its effective tax rate is below 10% or it sits in a listed tax haven. In most EU guides here, CFC rules only reach a genuine foreign corporation, which is why a Georgian IE - no separate legal personality - usually sits outside them. Kazakhstan's rule turns on the foreign structure's tax rate, not its legal form, so an IE does not obviously get the same pass. Georgia's 1% IE rate, and its 15% LLC distribution rate, both sit at or below the 15% line Kazakh law sets for exempting a treaty-country entity (75% of Kazakhstan's 20% corporate rate) - neither clears that bar with room to spare, making this a live planning question rather than one an IE resolves automatically.
Kazakhstan's CFC exemption instead runs through a periodically updated whitelist of jurisdictions not considered to have preferential tax regimes, refreshed for 2026-2027. We could not confirm whether Georgia appears on it, so treat CFC exposure as an open question to check directly.
Currency reporting is a separate, practical trap worth naming plainly. Cross-border transfers of 10,000 USD or more are subject to reporting to the National Bank, and a foreign exchange contract for export or import worth more than 50,000 USD requires formal accounting registration with a servicing bank. Invoicing a Georgian entity's clients, or receiving payment through one, at this scale is not something to set up informally - the contract itself needs to be registered on the Kazakh side.
The treaty between Kazakhstan and Georgia entered into force on 5 July 2000, confirmed both on Kazakhstan's own State Revenue Committee treaty list and on Georgia's Ministry of Finance list - see Georgia's double tax treaties for how a dual-residency dispute actually gets resolved.
The steps, in order
- Rule out Astana Hub or the AIFC first if you run an actual technology company rather than freelancing solo - either could beat Georgia outright for the right activity profile.
- Confirm your activity qualifies for Small Business Status. Consulting, legal, medical and licensed activities are excluded outright.
- Get a direct answer on CFC exposure before choosing a structure. Kazakhstan's broad definition means an IE does not automatically clear this the way it does elsewhere.
- Register the Georgian structure. In person, a few days; under power of attorney through remote company registration, two to three weeks.
- Close the Kazakh centre-of-vital-interests test properly - citizenship alone does not keep you resident, but property, family and residence permit ties together can.
- Register any cross-border contract above 50,000 USD with a Kazakh servicing bank before relying on it for ongoing payments.
- File your final Kazakh return covering the period you were still resident that year.
- Set up Georgian monthly compliance, which runs independently of the Kazakh side.
Timeline and cost
The Georgian side is fast - a few days in person, two to three weeks remotely. The Kazakh side is where the real planning time goes: 2026's tax code changes mean the numbers above should be confirmed close to the date you actually register, and the CFC and currency-registration questions are worth resolving before money starts moving between the two countries rather than after.
We'll check whether Astana Hub or the AIFC beats Georgia for your specific activity, confirm your CFC exposure under Kazakhstan's broader definition, and tell you plainly what structure holds up before you register anything here.
See what it costs
The verdict for a Kazakh national
Georgia works with conditions for a Kazakh national, and the condition is genuinely different from the rest of this cluster: rule out your own country's alternatives first. A real technology company that clears Astana Hub's 90% IT-revenue test may do better staying inside Kazakhstan's own regime than moving anything abroad. For a solo freelancer who does not meet that bar, the roughly 28% all-in Kazakh burden against Georgia's 1% is still a wide gap worth closing - but Kazakhstan's unusually broad CFC definition means the structure question needs a real answer, not an assumption carried over from how IE-versus-LLC works in the EU guides in this cluster.
The treaty is in force, the currency-reporting rules are mechanical rather than prohibitive, and none of this rules Georgia out. It just means the planning has to be more careful here than in most of the other 28 countries we cover.
For the other guide in this cluster where the usual IE-versus-LLC shortcut does not simply resolve the CFC question, see moving from Brazil to Georgia. Our full country-by-country guide compares the treaty position and headline trap across every country we cover, and a free consultation is the fastest way to check whether Astana Hub, the AIFC or Georgia actually fits your situation.
Key takeaways
- Astana Hub and the AIFC are genuine domestic alternatives for a real technology company - rule them out before assuming a foreign registration is the better move.
- A solo Kazakh freelancer under the 2026 simplified IE regime pays roughly 28% all-in once income tax, social tax and mandatory contributions are combined.
- Kazakh CFC rules reach individuals and explicitly include unincorporated foreign structures, so a Georgian IE does not automatically sit outside them the way it does in most EU guides in this cluster.
- Kazakh residency breaks only once the 183-day test and the centre-of-vital-interests test - citizenship, family, property and residence permit together - both fail.
- Cross-border contracts above 50,000 USD require currency-control registration with a Kazakh bank; transfers above 10,000 USD trigger reporting.
- The Kazakhstan-Georgia treaty has been in force since 2000, with a standard tie-breaker article.
Frequently asked questions
Is Georgia actually better than Kazakhstan's own tax regimes?
Not automatically. Astana Hub offers 0% corporate tax to qualifying IT companies with no local presence requirement, and the AIFC runs its own long-term tax holiday for participants. Either can beat Georgia outright for the right activity. Georgia's advantage is clearest for a solo freelancer or small services business that does not meet Astana Hub's 90% IT-revenue test.
How much does a Kazakh freelancer actually pay under the simplified regime?
Roughly 28% of turnover once individual income tax (10%), social tax (6%), and mandatory pension, social and health contributions are combined, based on the restructured 2026 tax code. These figures moved significantly with the 2026 reform, so confirm them close to your registration date.
Do Kazakh CFC rules reach a Georgian Individual Entrepreneur?
This is a genuinely open question. Kazakhstan's CFC definition explicitly covers unincorporated foreign structures, not just companies, turning on effective tax rate rather than legal personality - unlike most EU-style rules, which is why an IE does not clearly sit outside it here.
What is the CFC tax-rate threshold and does Georgia clear it?
Kazakhstan exempts a foreign entity from CFC treatment if it is registered in a treaty country and its nominal tax rate exceeds 75% of the Kazakh corporate rate - about 15%. Georgia's 1% IE rate and its 15% LLC distribution rate both sit at or below that line, so neither clearly clears the exemption on the rate test alone.
Is Georgia on Kazakhstan's CFC whitelist?
We could not confirm this from public sources. Kazakhstan updates a whitelist of jurisdictions not considered to have preferential tax regimes periodically, most recently for 2026-2027, and Georgia's status on it should be checked directly rather than assumed.
How is Kazakh tax residency broken?
Two tests apply: 183 days or more of physical presence in a rolling 12-month period, or a centre of vital interests in Kazakhstan - defined as citizenship or a residence permit, close family resident there, and property available for the family. Genuinely leaving means closing all of these, not just spending fewer days in the country.
What currency reporting applies to money moving between Kazakhstan and Georgia?
Transfers of 10,000 USD or more are subject to reporting to the National Bank, and any foreign exchange contract for export or import worth more than 50,000 USD requires formal accounting registration with a servicing bank before relying on it for ongoing payments.
Is there a tax treaty between Kazakhstan and Georgia?
Yes, in force since 5 July 2000, confirmed on both Kazakhstan's State Revenue Committee treaty list and Georgia's Ministry of Finance list, with a standard tie-breaker article for a genuine dual-residency dispute.
What is the difference between Astana Hub and the AIFC?
Astana Hub is a technology-focused regime available across all of Kazakhstan for qualifying IT companies, requiring no local office or staff. The AIFC is a separate financial-centre jurisdiction physically inside Astana, running its own tax holiday for financial and professional services participants, including certain individual exemptions on dividends and capital gains.
Should a Kazakh freelancer register a Georgian IE or an LLC?
Given how broadly Kazakhstan's CFC rules are drafted, this is not a question to decide by default the way you might in an EU country. Get a direct answer on how each structure is actually treated under Kazakhstan's rate-based CFC test before choosing, rather than assuming an IE is automatically clear of it.