Taxation of foreign assets: what has changed for investors in 2026

On August 6, Raison, together with the tax partners at EY, held a webinar on how the new rules affect the ownership, declaration, and structuring of foreign assets. The discussion was built around real questions from Raison clients, gathered in advance. Here is the essential takeaway on what is changing for investors right now.

The webinar covered three broad topics, each led by its own expert:

• Vladimir Fesenko and Yuliya Azimbayeva covered taxes: how the rules for declaring and calculating tax on investment income have changed.

• Doniyorbek Zulunov moved on to structuring capital — holding foreign assets through an SPV and the rules on controlled foreign companies.

• Dinara Tanasheva closed the session with a block on inheriting capital when assets are spread across several jurisdictions.

Below is the main point from each part.

A new level of transparency

The main change for investors with foreign assets is the level of transparency. Tax authorities now see far more information about taxpayers than they did a few years ago.

Kazakhstan receives data on its residents' accounts from more than 120 countries through the international automatic exchange of financial information: balances, income, and movement of funds. Domestically, this picture is supplemented by data from banks, brokers, and credit bureaus.

Information may arrive with a delay, but it does arrive. International exchange significantly increases the transparency of foreign financial accounts.

Yuliya Azimbayeva

For a conscientious investor, this means one thing: the accuracy of your reporting now deserves closer attention. Previously, many questions seemed purely technical — how to calculate the tax base, how to confirm tax withheld abroad. Now what matters is that the data in your declaration matches the information the tax authorities already have. Any discrepancies can draw extra attention, so the cost of a mistake has risen.

And there is not much time left: investors need to file their tax returns for the previous year by September 15.

Who needs to file a Form 270 declaration

Universal declaration in Kazakhstan already operates as a permanent regime, and the Form 270 declaration is the main document through which individuals report their income and foreign assets. Vladimir Fesenko suggested dividing those who need to file it into several categories.

• Those who have assets abroad or income on which tax was not withheld at the source.

• A new category: directors and participants of legal entities holding a stake of 10% or more, as well as their spouses. For this group, the requirements for disclosing financial information have become stricter.

• Those whose expenses for the year exceeded the large-purchase threshold. Under the current rules, this is about 80 million tenge. In that case, a declaration must also be filed.

The last two categories have a separate, most labor-intensive obligation — to disclose the sources of funds for their expenses. And not only for a single large purchase.

Even if I bought an apartment, I have to disclose the source of funding not only for that expense, but for all other expenses during the year, including every share I bought — where I got the money to buy it.

Vladimir Fesenko

In practice, this means that income, assets, and expenses must be consistent with one another. If expenses exceed declared income, the tax authorities may have questions.

What has become easier

One of the main changes in the investor's favor is the ability to account for gains and losses on securities on a combined basis.

Previously, tax was charged only on profitable transactions, while losses were not taken into account. Even if an investor ended the year in the red, taxes still had to be paid. Now, for stocks and bonds, you can combine profit and losses across all brokers for the year and pay tax only on the net financial result.

If my net result for the year is negative, then I won't owe any tax. That's great news.

Vladimir Fesenko

But the mechanism has an important limitation: it does not work for all assets. You cannot net derivatives (options, futures, forwards, swaps), digital assets, investment gold, currency, or real estate. For these, each transaction is still counted separately: if there is a profit, there is tax.

For a diversified portfolio, this is fundamental. Two portfolios with the same financial result can carry a different tax burden — it all depends on which assets they are made of.

At the same time, the calculation of an asset's initial cost was clarified. It can now include acquisition expenses, including broker commissions. And if the same asset was bought at different times at different prices, a single FIFO method applies: the first sold is the one bought earliest.

Where the difficulty remains

A common question for international investors is what to do if income tax has already been withheld abroad. Here, according to EY, no change could be achieved, although they lobbied for it.

Formally, to credit a foreign tax against the Kazakh one, you need a certificate issued or certified by the tax authority of the country where the tax was withheld. For securities that an investor holds through a broker, obtaining such a certificate is almost impossible.

In practice, thank goodness, the tax authorities don't hound you over this — they accept the broker's statement. But formally, they have every right to refuse because a broker's statement doesn't meet the law's requirements.

Vladimir Fesenko

So it is important for investors to distinguish between established practice and the formal requirements of the law. Especially when receiving dividends through foreign brokerage accounts.

Coming next — cryptocurrency and real estate

The automatic exchange of tax information between countries will continue to expand. A separate standard, CARF, has appeared for crypto assets: more than 50 countries have already joined it; in the EU, it took effect on January 1, 2026, and the first data exchange will take place in 2027. Kazakhstan is not part of it yet, but the direction is clear. A system for the international exchange of real estate data is also being prepared, with full launch expected closer to 2029–2030.

For the investor, this means transparency will only grow. So the sooner you put your reporting and ownership structure in order, the easier it will be to adapt to the new rules.

When an SPV is useful and how it can backfire

Direct ownership of assets is not the only option. An investor can set up an SPV — a separate company that owns assets and receives income from them. Doniyorbek Zulunov named two main reasons for using such a structure.

• Centralized ownership. A single company is convenient to manage and to pass on by inheritance: there is no need to re-register each asset separately.

• The netting problem. Within a company, you can combine gains and losses across different assets, including those an individual cannot net. For example, this may include venture investments, which are often structured not as ordinary securities.

But an SPV does not automatically mean a more favorable solution. It is a separate layer of taxes, administration, and reporting. In addition, you need to consider the rules on controlled foreign companies (CFCs).

If your foreign company is recognized as a CFC, you, as a tax resident of Kazakhstan, may be required to pay tax on its profit in Kazakhstan, even if the company distributed nothing to you.

An SPV can solve the netting problem and can be very useful and beneficial. But you must not lose sight of the taxation of the legal entity itself and the CFC rules.

Doniyorbek Zulunov

And here, it is important to keep in mind one of the key changes of 2026. Previously, companies with small profits up to roughly $1 million were exempt from the CFC rules. As of this year, the threshold has dropped sharply to about $1,500. This means that far more foreign companies may now fall under the CFC rules, and their owners may end up obligated to pay tax in Kazakhstan.

The takeaway is simple: the jurisdiction with the lowest corporate rate is not necessarily the most beneficial for the ultimate owner. A structure must be assessed as a whole: corporate and personal tax, CFC rules, administration costs, and inheritance considerations.

Inheritance: Why one will may not be enough

There's an English saying that there are two things in life you can't avoid — death and taxes. Today we'll talk about both, because they go hand in hand.

Dinara Tanasheva

The capital of a modern family is often spread across several jurisdictions: the family lives in Kazakhstan, the children study abroad, real estate is held in a third country, the portfolio is held with an international broker, and shares are in companies registered elsewhere. And each jurisdiction applies its own law to “its” assets. Real estate is almost always inherited under the law of the country where it is located. Shares in U.S. companies bring U.S. law with them, regardless of who the heir is.

Because of this, a single will drawn up in one country may not cover all foreign assets. And the tax authorities of several countries may claim part of the capital at the same time.

Without a plan, the decisions will be made not by your family, but by courts and tax authorities.

Dinara Tanasheva

A separate difficulty is that some decisions cannot be made after the fact. Once the owner has died, it is no longer possible to change their tax residency, move assets into a holding company or trust, or add a choice of governing law to the will. And tax obligations in some countries can arise even before the heirs actually receive the assets — and they will need liquidity to pay those taxes.

So estate planning is not about “drawing up a will,” but about aligning the will, the ownership structure, and the requirements of different jurisdictions in advance.

The bottom line for investors

The 2026 changes affect not a single rule but several aspects of managing capital at once. In short:

• Gains and losses on stocks and bonds can now be netted, with tax paid on the net result — but not for all asset classes.

• For large expenses, certain categories of investors must disclose the sources of all their spending for the year, not just a single purchase.

• Transparency has become total: what matters is not the invisibility of an asset, but the consistency of your reporting with the data the tax authorities already have.

• The threshold for exemption from the CFC rules has been sharply reduced, and far more foreign structures may now fall under them.

• Inheriting international capital requires a plan agreed upon across jurisdictions in advance.

There is no universal solution here — everything depends on the composition of assets, the jurisdictions involved, and the individual investor's situation. For many, the nearest practical step is the declaration due by September 15.

If you would like to understand how the new rules apply to your foreign assets or review your existing ownership structure, get in touch with your personal Raison manager. We will help identify which questions require separate analysis and, if needed, connect you with EY specialists.

This material is for informational purposes only and does not constitute individual tax, legal, or investment advice. Tax consequences depend on the specific investor's circumstances, the nature and location of the assets, applicable law, and the way it is applied. Information is current as of the webinar date — August 6, 2026.