ПВТ Беларуси vs Astana Hub Казахстана: какой режим действительно выигрывает для IT-аутсорсинга в 2026 году

Every other week, someone gets on a call with us and asks the same question: «Astana Hub is offering zero corporate tax. Why would we stay in HTP, or set up there in the first place?» It’s a fair question. It’s also the wrong one — or at least, it’s not the question they actually need answered.

The real question is: where does your delivery team belong, and how do you contract them without losing six months to legal setup? That’s a different problem, and the right answer depends on things most comparison articles skip — payroll math, where your customers will accept invoices from, whether you have someone on the ground who can run a foreign legal entity. So we wrote the comparison we wish founders had read before paying for two parallel relocation consultations.

The Two Regimes, in a Paragraph Each

Belarus High-Tech Park (HTP)

Established in 2005, extended by Presidential Decree No. 8 to January 1, 2049. HTP isn’t a building or a campus — it’s a legal regime. A resident company can register and operate anywhere in Belarus and still keep all the benefits. Today the park has over 1,000 resident companies and roughly 60,000 employees, and exports came in around $2 billion in 2024. Residents are exempt from corporate profit tax, VAT, and most other taxes; they pay 1% of revenue to the HTP Administration. Personal income tax stays at the flat 13% national rate, but social contributions are calculated on the country’s average wage rather than the actual salary — which is the part of HTP that quietly does most of the financial work. We’ve covered the full benefit list here.

Kazakhstan Astana Hub

Launched in 2018 as Kazakhstan’s flagship technopark, the Hub has over 600 active participants today. The headline: 0% corporate income tax, 0% VAT, 0% individual income tax for foreign employees, and 0% social tax for foreign workers. The catch lies in the fine print — those benefits apply only to income from a government-defined list of priority ICT activities, and the 100% CIT reduction holds only if all your income comes from those priority activities. One non-qualifying contract and you’ve got a problem. Kazakhstan’s 2026 Tax Code, analyzed in detail by Leinonen, extended the tax exemption on payments to non-residents through 2029, which preserves a meaningful planning window.

Side-by-Side: The Comparison Most Founders Don’t See

We’ve put this together from current Belarusian and Kazakh tax legislation, plus what we actually see when clients run the numbers. The table is dense — that’s deliberate. The differences are in the detail.

Where Astana Hub Genuinely Wins

1. Banking and counterparty comfort

In 2026, contracting through a Kazakh entity is, plainly, easier for a US or EU procurement team than contracting through a Belarusian one. This is a sanctions-and-perception issue, not a quality-of-regime issue, but it’s real. If your top three clients are running enhanced due diligence on every supplier and one of them just flagged «Belarus» in their compliance system, your Astana setup pays for itself the day it goes live. The Kazakhstan Hi-Tech Park benefits page is also honest about the export-oriented push.

2. AIFC and English law for venture capital

If you’re raising from Gulf or Asian LPs, or running a structure that needs international arbitration written into the cap table, the Astana International Financial Centre ecosystem — which sits next to Astana Hub geographically and culturally — does this well. HTP supports English-law instruments inside its regime, but it doesn’t have an international financial center bolted onto it.

3. The pitch is simply cleaner

«We pay zero corporate tax in Kazakhstan» is easier to put in a board deck than «We pay zero corporate profit tax in Belarus, plus 1% of revenue to a park administration, plus social contributions calculated against the national average wage…» The HTP math usually wins, but it takes a slide to explain. Astana takes one line.

Where HTP Wins for an Outsourcing Model

Now the part that does the work. If your business is selling engineering hours or building software products, four things matter more than the headline tax rate.

1. The payroll math (this is the big one)

HTP residents calculate social contributions on the country-average salary, not the engineer’s actual paycheck. For a senior dev paid $4,000 a month, that means contributions are computed against a base that’s a fraction of that figure — not the full $4,000. The savings compound across a team of 30 or 50 engineers and dwarf the difference between «0% CIT» and «exempt CIT plus 1%.»

Astana Hub zeroes out social tax — but only for foreign employees. If you’re hiring Kazakh nationals (which you will, that’s the point of being there), you’re paying standard social contributions on the full salary. Run the numbers honestly on a 30-person team and the gap is meaningful. We walk clients through this calculation in our payroll service overview.

2. No physical-presence drag

HTP is extraterritorial. You register the company anywhere in Belarus, and your team can be anywhere in the country. There’s no obligation to lease an office in a specific zone.

Astana Hub now expects a real Kazakh operational presence. That means a leased office, locally hired staff, an LLP that needs accounting, a director who can sign documents in Astana, and the overhead that comes with running a foreign legal entity in a country where most of your team doesn’t speak the language. For a 50-person dev shop, that overhead lands somewhere between annoying and prohibitive.

3. A more stable activity scope

HTP’s 12-area scope is broad and hasn’t moved much since 2017. You know what counts and what doesn’t. Astana Hub’s priority-activity list is narrower and government-defined, and the 100% CIT reduction is conditional on income coming exclusively from those activities. Pick up a consulting contract that doesn’t fit, and you’ve created a tax problem you didn’t have before. Anyone modeling Astana Hub into a financial plan should read the priority list before they put 0% in cell B12. 

4. Talent density that’s been compounding for two decades

Belarus has been training and exporting software engineers since the early 2000s. EPAM, Wargaming, Viber, Apalon, Maps.me, IBA, Itransition — every one of them came out of HTP. The Wikipedia entry on the Belarus High Technologies Park walks through the history if you want the long version. The result is a senior engineering bench that exists nowhere else in the region at this density. Kazakhstan’s IT ecosystem is younger and growing fast, but it isn’t there yet.

The EOR Angle (Where This Stops Being a Pure Comparison)

Here’s the thing most comparison articles miss: you don’t actually have to pick a regime. You have to pick how you employ people. That’s a different question, and it has a different answer for most companies than «set up an entity and apply for residency.»

Three scenarios cover almost everyone we talk to.

Scenario A: You want a Belarusian team without a Belarusian entity

This is the most common one. You’re a foreign company, you’ve identified Belarus as the right place to hire, but you don’t want to spend three months registering a UE, applying for HTP residency, and learning Belarusian labor law. Use an Employer of Record arrangement. Your provider hires the team under their own HTP-resident entity, the tax benefits flow through, and you sign one services contract. Onboarding runs 2–3 weeks instead of 3–6 months..

Scenario B: Kazakh contracts, Belarusian delivery

If your customers prefer to contract with a Kazakh entity but your engineering talent lives in Minsk, run a hybrid. A lightweight Kazakh LLP (or a partner) handles the customer-facing side. EOR in Belarus handles delivery. You get the Kazakh invoice your client wants and the engineering team you actually need. This is more setup than option A, but it’s a legitimate structure, and we’ve helped a few clients build it. The Spex.by comparison, goes deep on the legal side if you want a second opinion.

Scenario C: You’re actually relocating

If your founders are physically moving to Kazakhstan, your customers are in the region, and you want to build a Kazakh company — Astana Hub residency is the right call. An EOR in Belarus is the wrong tool for that job. We’d rather say so than try to talk you into something that doesn’t fit.

So, Belarus or Kazakhstan?

If you’re a 10–150-person IT services or product company looking for a delivery base — HTP, almost every time. The payroll mechanics, the talent density, the absence of a physical-presence requirement, and the fact that you don’t have to re-confirm residency every year all add up to a structure that just needs less attention to keep working.

If you’re raising from a regional capital, your customer base sits in jurisdictions that flag Belarus, or you’re personally relocating to Astana — Kazakhstan makes sense, and we’d be the first to tell you so.

And if you’re tired of the question and just want a team in Minsk under contract by next month, that’s the gap we fill. Our team handles HTP residency, payroll, compliance, and the actual hiring. Talk to us before you commit to a structure — twenty minutes on a call usually saves a quarter of legal fees.

Want more on the Belarus side specifically? We’ve got a primer on HTP membership, a deeper HR consulting overview, and the blog index if you’d rather poke around on your own.

Об авторе

John D.

Контент маркетинг менеджер

John D. - менеджер по контент-маркетингу в компании EOR.by. Имеет опыт создания контента и разработки стратегий на местном рынке и за рубежом, Он делится своим богатым знаниями, чтобы облегчить процессы компаний, стремящимся к развитию и масштабированию.