According to the Tax Code, profits of controlled foreign companies (CFCs) are subject to taxation in Kazakhstan. 

This rule does not apply to CFCs registered in a state with which Kazakhstan has an effective double-tax treaty, provided that the nominal income tax rate in such state is more than 15 percent.

For the purposes of this exemption, the Ministry of Finance of the Republic of Kazakhstan approved the list of countries that meet this requirement. 

The list includes 41 jurisdictions (out of 55 with which Kazakhstan has double-tax treaties), including, inter alia, the Netherlands, the Russian Federation, Singapore, Luxembourg and Switzerland (except for the cantons of Zug, Lucerne, Uri, Obwalden, Nidwalden, Appenzell-Auserrhoden, Appenzell-Innerrhoden, Valais).