Taxation Of Mining And Cryptocurrency Circulation In Kazakhstan. Part II

Following our previous article on recent developments in Kazakhstan's digital asset regulation, we present an overview of the taxation framework applicable to mining activities and cryptocurrency circulation in Kazakhstan as of 2026.

At a general level, the core taxes applicable to miners continue to apply, although several targeted amendments have been introduced to clarify specific aspects of the taxation framework and address practical issues that arose in the course of applying the previous rules.

Income Tax on Mining Activities

The very fact of receiving digital assets as a result of mining constitutes a taxable event that may give rise to income tax obligations. In other words, the acquisition of digital assets through mining is treated as the generation of income for tax purposes.

In this case, income is determined according to the following formula:

Income = number of digital assets received × their value

At the same time, as of 2026, the valuation of digital assets for tax purposes must be determined in accordance with the Rules for Determining the Value of Digital Assets, which entered into force on 1 January 2026.

Compared to the previous framework adopted in 2024, the updated Rules significantly clarify and centralise the methodology for determining the value of digital assets. In particular, the Rules introduce a broader list of digital assets subject to valuation and establish a methodology for determining the value of digital assets that are not included in that list.

Accordingly, the value of all digital assets received as a result of mining must be included in the taxpayer's aggregate annual income and is subject to income tax.

For legal entities, such income is subject to income tax at the standard rate of 20%. For inpidual entrepreneurs, starting from 2026, income derived from mining activities may be subject to inpidual income tax at progressive rates ranging from 10% to 15%, depending on the applicable tax regime.

At the same time, it should be noted that in 2026 the Tax Code provides a mechanism to prevent double taxation in the event of a subsequent disposal of digital assets that were previously obtained through mining.

If a taxpayer has already recognised income upon receiving digital assets as a result of digital mining, the subsequent sale or other disposal of such assets should not give rise to additional income tax. This approach is based on the assumption that the taxpayer has already paid tax at the moment the digital assets were generated. This mechanism is implemented through a rule under which income derived from the disposal of digital assets obtained through mining is excluded from the taxpayer's aggregate annual income. As a result, the taxation of mining activities effectively occurs at the moment the digital asset is created (mined), rather than at the stage of its subsequent sale.

Digital Mining Fee

In addition to corporate income tax on income derived from mining, persons engaged in digital mining activities are also required to pay a separate tax known as the digital mining fee.

For the purposes of this fee, the tax base is determined based on the volume of electricity consumed by the miner in the course of mining activities. The general rate remains unchanged and amounts to KZT 2 per kilowatt-hour (kWh) of electricity consumed. And a reduced rate of KZT 1 per kWh applies where electricity is generated from renewable energy sources or from the miner's own generating installations.

A notable change introduced in 2026 a significantly increased, effectively penalty rate, amounting to KZT 25 per kWh of electricity consumed. This rate applies in cases where certain regulatory requirements are violated.

In particular, the penalty rate may apply if:

• the miner operates without electricity metering devices, or
• the metering devices are faulty or inoperative.

Taxation of Cryptocurrency Transactions

As of 2026, the tax legislation of Kazakhstan expressly provides rules for determining taxable income arising from transactions involving digital assets for income tax purposes.

In particular, taxable income may arise in several situations, including the sale of cryptocurrency, the contribution of digital assets to the charter capital of a legal entity, or during certain reorganisation transactions (such as mergers, acquisitions, pisions). In each of these cases, the resulting income may be subject to income tax.

The Tax Code establishes specific rules for determining taxable income depending on the type of transaction involved. For example, in the case of the sale of cryptocurrency, taxable income is determined as the positive difference between the sale price of the digital asset and its initial acquisition cost.

The VAT treatment of digital asset transactions has also changed as of 1 January 2026.

Prior to this date, the tax legislation expressly provided a VAT exemption for transactions involving the sale of digital assets.

However, the new Tax Code significantly narrows the scope of this exemption. Under the updated rules, the VAT exemption now applies only to services provided by digital asset exchanges licensed by the AIFC.

In all other cases, transactions involving the sale or transfer of digital assets may be subject to VAT at the standard rate of 16%.

Changes in Reporting Requirements

Digital mining pools are also subject to specific reporting obligations. In particular, they are required to submit information to the tax authorities regarding the distribution of digital assets among participants of the mining pool. Such information must be submitted no later than the 25th day of the month following the reporting month.

On 20 February 2026, the Minister approved a new reporting form for submitting this information. The form establishes the new format and content of the data that digital mining pools must provide to the tax authorities regarding the allocation of mined digital assets.

The requirement to submit this information using the new reporting form is expected to enter into force on 25 April 2026.

Conclusion

While the overall tax framework remains largely unchanged, the new rules provide greater detail regarding the valuation of digital assets, the prevention of double taxation for mined assets, and the taxation of transactions involving digital assets.

In light of these developments, inpiduals and companies engaged in cryptocurrency mining or digital asset transactions should carefully review the updated provisions of the tax legislation and ensure that their activities are structured in compliance with the new requirements.

Sources:

1. Tax Code of the Republic of Kazakhstan, Code of 18 July 2025 No. 214-VIII ZRK https://adilet.zan.kz/rus/docs/K2500000214
2. Order of the Minister of Finance of the Republic of Kazakhstan dated 29 March 2024 No. 172 "On Approval of the Rules for Determining and Publishing the Value of Digital Assets and the List of Their Types" https://adilet.zan.kz/rus/docs/V2400034214
3. Order of the Minister of Finance of the Republic of Kazakhstan dated 20 February 2026 No. 119 "On Approval of the Form of Information on Digital Assets Distributed by a Digital Mining Pool between Persons Engaged in Digital Mining Activities Submitted to the State Revenue Authorities" https://adilet.zan.kz/rus/docs/V2600038031
4. Order of the Minister of Finance of the Republic of Kazakhstan dated 28 October 2025 No. 634 "On Approval of the Forms of Information Submitted to the State Revenue Authorities by Digital Asset Exchanges and Other Participants of the Astana International Financial Centre on Transactions Conducted by Residents and Non-Residents on Digital Asset Exchanges and Remuneration Paid in Connection with Digital Asset Activities, and the Rules for Their Submission" https://adilet.zan.kz/rus/docs/V2500037274

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.