Tax optimization for properties with low book value

We will help you to optimize the IIT or CIT

Digital technologies are one of the priority areas of the AIFC.

In construction, cash payments prevail and due to the lack of closing accounting documents, not all cash costs were borne by the book value of the property. Accordingly, on sale, a difference arises between the book and market value. How to optimize the IIT or CIT in such cases?

AIFC participants are exempt from value-added tax on shares and dividends from AIFC participants. This approach allows you to optimize taxes on assets and real estate, where the book and market values can differ greatly. In Western countries, Special Project Companies have a single activity similar to a holding activity, i.e. ownership of assets. It is easier and more profitable for owners to sell shares in the SPC than to sell the rights to real estate, the movement of which may result in various taxes.

SPC Taxation

SPCs are not taxed, as they have the purpose of owning assets, i.e. they cannot engage in any other commercial activity. It is much easier to sell shares in SPC than all real estate. Since SPC does not have a director and a physical address, the administration is carried out by licensed consulting companies (Company service providers). Our company has such a license and we are ready to optimize your taxes.

Creation of SPC at the AIFC

Benefits of setting up an SPC at the AIFC

Using SPC at the AIFC to run your business

Acquisition, possession or disposal of any asset (tangible or intangible)
Obtaining any type of financing (banking or capital markets), granting any type of collateral right to its assets, providing any refund or similar support to its shareholder (s) or any of its subsidiaries, or entering into any type of hedging agreements
Funding the Initiator or another SPC
Performing the functions of a trustee or agent for any participant in the Transaction
Other activities approved in writing by the Registrar of Companies

Limited liability
No requirements for the minimum size of the authorized capital
No requirements for renting an office in the AIFC, which allows you to reduce money, time, and other costs. Also, the SPC is not obliged to conduct the main activity (principle business activity) in the AIFC
No requirements for holding the annual meeting of shareholders
No restrictions on foreign ownership
No requirements for providing annual reports to the Registrar of Companies

Capital gains income from the sale of

of securities that are on the date of sale in the official lists of the stock exchange.
shares or interests in the authorized capital of participants - legal entities registered in accordance with the current law of the AIFC

Dividends

on securities that are on the date of accrual in the official lists of the stock exchange
on shares or interests in the authorized capital of participants - legal entities registered in accordance with the current law of the AIFC

AIFC Benefits

Location & Untapped Opportunities
Kazakhstan is committed to promoting the growth, diversification and development of the wider economy, creating wide-reaching business opportunities
International Standard Regulatory Framework
Regulator of AIFC, AFSA, a signatory to the IOSCO's MMoU, an internationally recognised quality badge for the standards of securities market regulation. Other memberships include IFSB, IAIS, and AAOIFI
Independent AIFC Court and IAC
Independent and best-in-class dispute resolution and enforcement mechanisms through the AIFC Court and International Arbitration Centre (IAC)
Value Creation through Bankable Deals and Co-investment Opportunities
Access to bankable investment opportunities and support with co-investment opportunities and local engagement to drive value creation
100% Foreign Ownership
100% foreign ownership of AFSA registered entities is allowed under the regulation
Flexibility to Operate from Multiple Offices in Kazakhstan
Operate from a different city or retain office outside Nur-Sultan while branches benefit from lower capital requirements in the AIFC providing flexibility to conduct business in different regions of the country
Capital Flows & Currency Regime
Capital flows, repatriation of profits and flexible currency regime
SPCs providing Highly Flexible Solutions for Project Financing in Infrastructural Projects
AIFC's highly flexible SPC regime suitable for infrastructure project investment, corporate restructuring, capital raising and securitisation
Tax-free management of fund assets
Licenses professional asset managers
Migration and Redomicile Permitted
AIFC permits redomiciling an entity from a different jurisdiction to the AIFC, allowing to transfer all legal rights and liabilities to the new entity
Low Operational Cost
Considerably low operational cost compared to other regional financial centres, including Dubai, Abu Dhabi, Singapore, Qatar and Moscow
Double Taxation Treaties
Kazakhstan has entered into bilateral treaties to avoid double taxation with 53 countries