Taxation of Kyrgyz Passport Holders Residing Abroad

15.06.2026

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Problem Statement

The Tax Code of the Kyrgyz Republic (Law No. 3 dated 18.01.2022) formally establishes a citizenship-based taxation principle, similar to the U.S. model. This theoretically means that all Kyrgyz citizens are required to pay taxes on their worldwide income, regardless of their country of residence.

This issue is particularly relevant for individuals who have obtained Kyrgyz citizenship through second citizenship programs or other legal grounds, and who have no real connection to Kyrgyzstan in terms of residence or income sources.

Current Status

In practice, the situation is different. Due to a series of amendments to the Tax Code, the following approach has effectively developed:

If a Kyrgyz passport holder does not reside in Kyrgyzstan and does not earn income from Kyrgyz sources, there is effectively no taxable base. As a result, there is currently no obligation to pay taxes or file tax declarations.

However, it is important to note that there is no explicit legal provision that clearly exempts non-resident citizens from all obligations. This is a matter of established administrative and enforcement practice, based on the interpretation of existing rules as a whole.

Risks

Legal uncertainty still exists.

An interagency working group is currently reviewing possible harmonization of these rules. Two main scenarios are being discussed:

1.  The Tax Code will be clarified to confirm the principle of territorial taxation (taxation only on income sourced in Kyrgyzstan), or
2. Kyrgyzstan may move toward a full citizenship-based taxation model, similar to the U.S., where all citizens are taxed on worldwide income regardless of residence.

The second scenario would significantly change the current framework.

Any legislative changes would not take effect before January 1 of the following year and would go through the full legislative process, including parliamentary readings and presidential approval. This provides time for preparation.

What to Do Now

There is currently no need to pay taxes or file declarations in Kyrgyzstan, provided there is no income sourced from within the country.
However, monitoring legislative developments is essential.

REVERA Law Group monitors changes in Kyrgyz tax legislation and proactively informs clients about significant amendments. The firm also advises on tax residency matters and interactions with Kyrgyz tax authorities.

Disclaimer: This material is for informational purposes only and does not constitute legal advice. Current as of May 2026. Legal basis: Tax Code of the Kyrgyz Republic, Law No. 3 dated 18.01.2022 (as amended).