10% standard profit tax on net income (2-6% simplified turnover-based regime available without income limits; residents of the High Technology Park and Creative Industries Park are exempt).
Flat 10% on most individual income.
12% standard, with certain supplies zero-rated (exporters, education, medical, agriculture, and High Technology Park/Creative Industries Park activity).
An individual is resident if physically present in Kyrgyzstan for 183 days or more in a 12-month period, confirmed via three independent sources. Kyrgyz citizens are generally taxed on worldwide income regardless of their tax residency status, confirmed via GSL - a citizenship-linked rule distinct from the ordinary residency test. Resident companies are taxed on worldwide aggregate annual income (profit tax) at 10%, confirmed via GSL.
Confirmed via two independent, direct sources: Freeman Law's tax treaty summary states plainly "CFC Rules. No," and Orbitax separately and directly states "There are no Controlled Foreign Company rules in Kyrgyzstan." This is a well-corroborated "No" rather than an inferred gap.
No statutory thin capitalization ratio was identified in available sources this session.
No domestic FBAR/Form 8938-equivalent requiring Kyrgyzstan residents to self-report their own foreign accounts was identified. Foreign exchange regulation is relatively mild - non-residents can freely buy or sell foreign currencies and open foreign-currency bank accounts, confirmed via GSL. Kyrgyzstan has not signed the OECD's Multilateral Convention (MLI), confirmed via the same source. Separately and independently of local law, US citizens and Green Card holders with Kyrgyzstan accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of local requirements.
Kyrgyzstan has approximately 30 double taxation agreements, confirmed via TaxAtlas. The United States has a tax treaty in force with Kyrgyzstan, confirmed directly via Freeman Law, with specific rates confirmed for dividends (10%), interest (10%), and royalties (10%) under that treaty. Transfer pricing follows an arm's-length standard generally aligned with OECD guidelines, also confirmed via Freeman Law. Application of double taxation treaties can reduce or eliminate the standard withholding rates otherwise applying to non-resident income, confirmed via GSL.