How to Maintain Astana Hub Residency Status: A Practical Guide

Obtaining Astana Hub status is only the beginning

Astana Hub membership gives IT companies access to one of Kazakhstan’s most favourable tax regimes, including tax incentives for corporate income tax (CIT), VAT, employees’ individual income tax (IIT), social tax in respect of foreign employees, and certain payments to non-residents, including royalties and dividends. The regime applies across Kazakhstan, so a company from any region of the country may participate.

However, signing the agreement with Astana Hub and being included in the register are only the first steps. The tax benefits are not maintained automatically: the company must continuously comply with the applicable requirements. During monitoring, Astana Hub looks beyond the formal description of the business and assesses the actual business model: what product is being developed, what services are actually provided, how revenue is generated and whether IT activities form the core of the business.

Since 2026, the requirements have become stricter: at least 90% of the participant’s income must come from priority activities, and separate accounting must be maintained. Below is a practical overview of what companies need to do to retain their status and tax benefits.

1. Carry out the activities stated in the business plan

The business plan submitted when joining Astana Hub remains relevant throughout the company’s participation. Astana Hub uses it as a benchmark when assessing the company’s actual activities.

Risk arises where a company stated that it was developing its own product and subsequently:

• changes its product, service or monetisation model;
• generates significant revenue from new activities not included in the business plan;
• effectively stops developing the project for which Astana Hub status was obtained.

A second benchmark is the approved list of priority ICT activities. Being an “IT company” does not in itself guarantee compliance: each revenue stream must correspond to a specific activity on the list, such as software development, implementation and maintenance of information systems, data processing, cloud and AI solutions, GameDev and similar activities. Astana Hub has given examples where general consulting services and training outside the ICT sphere were treated as a breach of the participation requirements.

If the business model changes, the company should assess this in advance and determine whether the business plan needs to be updated and whether Astana Hub must be notified or its approval obtained. The company should also be able to demonstrate that the project is genuine, including through a suitably qualified team or contractors and documented rights to the software product or other intellectual property.

2. Comply with the 90/10 rule and maintain separate accounting

At least 90% of total annual income must come from priority ICT activities, while no more than 10% may come from other activities. Exceeding the 10% threshold may result in the loss of tax benefits, a move to the general tax regime and a risk of losing Astana Hub status. Non-core income is not prohibited, but its share must be monitored throughout the year rather than only at year-end.

Examples of priority income include:

• software development, modification and maintenance
• SaaS subscriptions and access to digital platforms
• implementation of information systems
• cloud solutions, AI analytics and data processing
• game development and specialised IT training

Examples of non-core income include:

• sales of equipment and goods
• installation and engineering works
• lease and sublease of premises
• ordinary consulting unrelated to an IT product
• resale of third-party solutions without proprietary development

The 90/10 rule cannot be demonstrated without separate accounting. The accounting function should track revenue by activity, project and contract and be able to produce the calculation of the relevant income share at any time. Recording all receipts under a single general category creates a direct risk of a dispute with Astana Hub or the tax authorities.

The supporting documents are equally important. Contracts, acceptance certificates, invoices and electronic invoices should make clear that the income relates to ICT activities. Descriptions such as “consulting services”, “service services” or “technical support” without reference to the relevant software product may create a risk even where the work is substantively ICT-related. Where a transaction combines software development and the supply of equipment, the scope and value of the two components should be separated, either in separate agreements or at least in separate specifications.

3. File reports and meet obligations to Astana Hub

Astana Hub participants have four regular obligations towards the Fund, and a breach of any of them may be treated as non-compliance with the participation requirements.

1. Quarterly activity reports. They must be complete, timely and consistent with contracts, acceptance certificates and accounting records. Changes in the business should be disclosed rather than concealed: discrepancies between the report and supporting documents may be identified as soon as documents are requested.
2. Membership fees of 1% payable quarterly. The risk relates not only to non-payment or late payment, but also to an incorrectly determined calculation base.
3. Counter-obligations. These must not only be performed but also supported by evidence of performance.
4. Audit confirmation where income exceeds KZT 100 million. An annual auditor’s report (agreed-upon procedures report) confirming compliance with the ICT activity list, revenue structure and the conditions for applying the tax benefits is required. The deadline is 1 July, together with the quarterly report for Q2.

Astana Hub may also request primary documents, including contracts, acceptance certificates, invoices and electronic invoices. Ignoring the Fund’s requests and notices creates a risk in itself. Companies should therefore appoint a person responsible for communication with Astana Hub and keep the relevant documentation organised.

What most often leads to the loss of tax benefits

• non-core income exceeds 10%, for example because of a large equipment sale or the lease of premises;
• actual activities depart from the business plan or fall outside the list of priority activities;
• contracts and acceptance certificates are drafted too broadly or combine core and non-core services without separating their value;
• there is no evidence of rights to software or IP, or no team proportionate to the declared development activities;
• reports are late, incomplete or inconsistent with the accounting records;
• membership fees have not been paid or counter-obligations have not been fulfilled;
• the audit report is not submitted where income exceeds KZT 100 million, or the audit identifies discrepancies.

Resident checklist

Before signing each contract: Determine whether the income is core; describe the subject matter by reference to the specific ICT activity; separate the value of core and non-core work.

Monthly: Allocate revenue by activity in the separate accounting records; retain acceptance certificates, invoices and technical evidence.

Quarterly: Check the cumulative share of non-core income; file the Astana Hub report; pay the 1% membership fee; reconcile the report with the accounting records.

Annually, by 1 July: Where income exceeds KZT 100 million, submit the auditor’s report together with the Q2 report.

Annually: Reconcile actual activities with the business plan and the list of priority activities; check performance of counter-obligations and rights to software/IP.

When the business model changes: Before launching a new activity, assess its impact on the 90/10 rule and, where necessary, update the business plan and notify Astana Hub.

For transactions with non-residents: Check the payment classification, the recipient’s status and the conditions of the relevant tax benefit.

When Astana Hub requests information: Respond within the required timeframe and provide the requested documents.

Conclusion

Astana Hub membership is an ongoing compliance regime rather than a one-off registration. The tax benefits remain available while the business plan, contracts, accounting, reporting and actual activities tell the same story: the company genuinely carries out priority ICT activities and derives at least 90% of its income from them.

Residents should therefore continuously review new contracts before signing, analyse their revenue structure on a quarterly basis and assess any changes to the business model in advance. A periodic legal audit of the contractual framework and revenue structure is significantly less costly than additional tax assessments under the general regime and the loss of Astana Hub status.