Memo on Preserving Astana Hub Tax Benefits
The status must not only be obtained, but also maintained.
Obtaining Astana Hub participant status is only the first step. Tax benefits are not granted automatically on an ongoing basis; they are maintained only if the company continuously complies with the requirements of the regime.
This includes carrying out declared ICT activities, generating the majority of income from priority activities, properly maintaining documentation, submitting required reports, and fulfilling all obligations to Astana Hub.
In other words, after registration, the company must be able to demonstrate that its actual operations correspond to the project originally declared during admission to Astana Hub.
During monitoring, regulators assess not only the formal description of the business but also the real revenue model: what product is being developed, what services are actually provided to clients, how income is generated, and whether IT activity is the core of the business.
| Astana Hub separately notes that from 2026 participants must derive at least 90% of their income from priority activities and maintain separate accounting. |
Practical takeaway: tax benefits are preserved when documentation, accounting, contracts, reporting, and actual business activity all tell the same consistent story - that the company is genuinely engaged in core IT activities.
Key Conditions for Maintaining Astana Hub Tax Benefits
To retain tax incentives, an Astana Hub participant must manage several compliance areas simultaneously:
1. 90/10 Rule Compliance
At least 90% of total annual income must be generated from priority ICT activities, while no more than 10% may come from non-core activities. Exceeding the 10% threshold for non-profile income may result in loss of tax benefits.
2. Alignment with the Declared Business Plan
If a company declared software development at registration but later generates significant revenue from consulting, equipment sales, leasing, or other non-core services, this may jeopardize its participant status.
3. 3. Compliance with the List of Priority Activities
The company must regularly verify that its services and products fall within the approved ICT priority areas. Astana Hub has noted cases where general consulting or training outside ICT was deemed non-compliant with participation requirements.
4. Proper Documentation of Contracts and Primary Documents
Contracts, acts, invoices, and other supporting documents must clearly show that income is derived from ICT activities. Vague descriptions such as “consulting services,” “business support,” or “service provision” may raise compliance concerns if they do not clearly reflect ICT scope.
5. Proper Accounting and Tax Reporting
Participants are required to maintain accurate accounting and tax records. Violations or incorrect reporting may lead to exclusion from the technopark. Authorities may request primary documents, including contracts, acts, e-invoices, and invoices for verification.
6. Timely Reporting and Compliance Obligations
Participants must submit regular activity reports, fulfill all obligations, and pay membership contributions quarterly at a rate of 1%.
7. Audit Requirement for Revenue Above 100 Million KZT
Participants with annual revenue exceeding 100 million KZT must undergo an annual audit/verification confirming compliance with priority activity requirements and tax benefit conditions. The audit report must be submitted annually by July 1, as part of the Q2 reporting cycle.
Typical Mistakes That May Lead to Loss of Astana Hub Tax Benefits
In practice, risks usually arise not from a single major violation, but from the gradual accumulation of inconsistencies between the declared project and the company’s actual activities.
Main risks
1. Non-core income exceeds 10%
For example, the company starts generating a significant share of revenue from equipment sales, installation services, leasing, or general consulting.
2. Actual activities differ from the business plan
The company declared software development but in reality provides services that are not included in the list of priority ICT activities.
3. Overly generic contracts and documents
Contracts or acts do not clearly indicate that the services relate to IT/ICT activities.
4. Mixing core and non-core services in one contract
For example, software development, equipment supply, and installation are included under a single contract without separating scope and pricing.
5. Lack of IP or software ownership confirmation
This is especially critical when tax benefits are linked to income from intellectual property.
6. Insufficient team or expertise evidence
If a company claims large-scale IT development but cannot demonstrate relevant employees, contractors, or technical capabilities, this may raise compliance concerns.
7. Late reporting
Failure to submit reports on time or incomplete reporting may create risks for maintaining status.
8. Non-payment of membership fees
9. Failure to fulfill mutual obligations
10. Failure to provide audit report (for revenue above 100 million KZT)
Astana Hub notes that missing audit reports or identified inconsistencies may lead to questions regarding the legitimacy of tax benefits, potential violations of participation conditions, and additional inquiries from the Fund and competent authorities.
Conclusion
To preserve Astana Hub tax benefits, a company should treat its participant status as an ongoing compliance regime rather than a one-time registration.
The safest approach is to establish a robust internal control system in advance: review new contracts before signing, analyze revenue structure on a quarterly basis, maintain technical and accounting evidence, and promptly update the business plan whenever the operating model changes.
Any modification of the IT product or the launch of new business activities requires timely updates to documentation and adjustments to the business plan submitted to the technopark.
| REVERA Kazakhstan provides comprehensive legal support for Astana Hub participants - from setting up internal compliance and accounting frameworks to defending participant status during regulatory monitoring. |
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