The Astana International Financial Centre (AIFC) reproduces the DIFC and ADGM model on Kazakh soil: a separate jurisdiction with its own law built on common law principles, an independent court, the AFSA regulator, the AIX exchange and tax exemptions running to 2066. The centre sits physically in Astana; legally, most private-law questions are resolved inside its own legal order. How far the analogy with Dubai, Abu Dhabi, Doha and GIFT City actually runs is set out in the comparison below.
The construct has been tested by volume: by the end of 2025 the centre held more than 4,900 registered companies from 90+ countries, with roughly $20 billion channelled into the economy through the platform. For financial and crypto business with a Central Asian nexus the centre supplies a ready regulatory perimeter; everyone else has to price the benefits line by line.
Key parameters of the AIFC regime:
| Parameter | Value |
|---|---|
| Legal basis | Constitutional Statute No. 438-V of 7 December 2015; own AIFC Acts on common-law principles of England and Wales; working language English |
| Court and arbitration | AIFC Court outside Kazakhstan's judiciary (led by Lord Burnett of Maldon) plus the International Arbitration Centre; judgments enforced with no recognition step |
| Taxes | 0% CIT and VAT on listed financial services to 01.01.2066 (art. 6); trading and service revenue taxed on general terms |
| Substance | Since 2022, CIGA carried out in the centre plus expenses and headcount proportionate to business volume (Rules on the Substantial Presence) |
| AFSA licences | Application $7,000 (managing investments) to $98,000 (DATF crypto exchange); annual supervision fees from $1,400 |
| Company registration | Private company $500 online via portal.aifc.kz ($1,500 on paper); no minimum capital; registered office in the centre required |
| Scale | 4,900+ companies from 90+ countries; about $20 billion channelled into the economy (end of 2025) |
| ITRP for individuals | Investment from $60,000; five-year investor visa; tax residency at 90 days' presence instead of 183 |
Concept: common law inside Kazakhstan
The centre was created by Constitutional Statute No. 438-V of 7 December 2015; the Constitution itself was amended in March 2017 to accommodate it. Its own law applies inside the perimeter: AIFC Acts are built on the principles, rules and precedents of the law of England and Wales and the standards of leading financial centres, and the working language is English. Kazakh civil legislation applies subsidiarily, while public law — criminal and administrative — applies in full.
Dispute resolution sits outside the national system. The AIFC Court is not part of Kazakhstan's judiciary: a first instance with a Small Claims division for claims up to $150,000, an appellate court, and common-law judges on the bench led by Lord Burnett of Maldon, former Lord Chief Justice of England and Wales. Judgments are enforced in Kazakhstan under the same procedure as acts of the national courts, with no recognition step; appellate rulings are final. The International Arbitration Centre (IAC) operates alongside, with awards enforced under the rules for Kazakh arbitral awards. The court and the IAC handled 1,282 cases in 2025.
The tax regime until 2066
Article 6 of the Constitutional Statute fixes the exemptions until 1 January 2066 — a horizon written into a constitutional-level norm. The perimeter of relief looks as follows:
| Who | What is exempt until 01.01.2066 |
|---|---|
| Financial participants | CIT and VAT on income from financial services on the approved list (~34 categories: banking, insurance, brokerage, asset and fund management, underwriting, custody) |
| Ancillary providers (legal, audit, consulting) | CIT on services to AIFC bodies and financial participants |
| Foreign employees of financial participants | personal income tax on employment income |
| Individual investors | PIT on dividends and gains on stakes in AIFC participants and on AIX-listed securities (subject to the statutory criteria) |
| AIFC bodies and participants supplying the services listed in art. 6(3) and 6(4) | property and land tax on facilities located inside the centre |
In practice the edges of the relief matter more than the list itself. Trading and service revenue is taxed on general terms. For digital asset exchanges the AIFC expressly carves out part of the exemptions — a DATF operator has to model its tax position separately. Salaries of Kazakh employees are taxed normally and social payments remain due.
Since 2022 the relief has been conditional on real presence: the Rules on the Substantial Presence require core income-generating activities (CIGA) to be carried out in the centre, with expenses and full-time headcount proportionate to the volume of business. The regime is deliberately assembled as a BEPS-compliant preferential one, against OECD/G20 standards.
The 2026 tax reform sharpened the arithmetic: under the new Tax Code the standard VAT rate is 16%, CIT is 20% and 25% for banks, and PIT turned progressive (10%, and 15% above 8,500 MCI of annual income). The AIFC exemptions are written into the constitutional statute and the reform did not repeal them, so the gap between the general regime and the centre has widened.
AFSA licensing
AFSA (the Astana Financial Services Authority) combines the roles of financial regulator and companies registrar. Licensable categories split into regulated activities — accepting deposits, providing credit, dealing in and managing investments, custody, trust services, fund management, insurance, Islamic finance, payment services — and market activities: exchange, clearing, crowdfunding and operating a Digital Asset Trading Facility (DATF). Ancillary services go through a lighter authorisation.
The cost of entry is set by the fees rules as amended with effect from 1 December 2025: an application for a banking licence (accepting deposits) costs $21,000, broker-dealer $14,000, managing investments $7,000, fund management $7,000–10,000 and a crypto exchange (DATF) $98,000. Annual supervision fees run from $1,400 for advisers to $20,000 for exchange infrastructure, plus a variable component tied to turnover.
The FinTech Lab is a regulatory sandbox for models that no existing licence fits. Entry is cheaper than the full regime: a $2,000 pre-application fee, an application fee of 30% of the standard fee for the corresponding activity, and approved individuals at $200 against $500 in the full regime.
The centre opened the region's crypto track first. Binance Kazakhstan was the first global platform to complete full AFSA authorisation — trading facility, broker-dealer and digital asset custody under one licence; other operators work inside the perimeter as well, including Bybit Kazakhstan. Over the first nine months of 2025 digital asset transaction volume on the centre's platforms reached $6.8 billion across 192,400 clients. The licence map, the rules for platforms and fiat off-ramps are covered in Kazakhstan crypto licences; the banking side of such projects is profiled in Alatau City Bank.
An AIFC company against an LLP
Registration runs online through portal.aifc.kz: a private company costs $500 ($1,500 on paper) and the register of participants is public at publicreg.myafsa.com. The menu of forms is wider than the Kazakh corporate default: private and public companies, LP, LLP, special purpose companies, investment companies, funds and foundations. There is no minimum capital for a private company; a registered office inside the perimeter is mandatory.
For a non-licensable company the procedure comes down to four steps:
- Beforehand: settle the activity and check whether it requires an AFSA licence; prepare the ownership structure, passports and proof of address for beneficial owners, and a business plan.
- File through the centre's portal — articles on the AIFC template, details of directors and shareholders, and a registered-office agreement with an accredited provider.
- Clear the Registrar of Companies review: beneficial-owner compliance, source of funds and, where needed, follow-up requests.
- Receive the certificate of incorporation and the public register entry; then Kazakh tax registration and account opening.
A Registrar refusal usually traces back to an opaque ownership chain or to an activity that in fact requires a licence. The decision is appealable to AFSA and then to the AIFC Court. Licensable activities add AFSA authorisation on top: business plan, prudential capital, approval of individuals for key functions and interviews — in practice several months.
The comparison with a conventional Kazakh LLP turns on the type of income. For non-licensable trade and services an AIFC company delivers English contract law and access to the AIFC Court, with zero tax relief: income outside the list is taxed on general terms while substance requirements and fees add cost. For regulated financial business the comparison inverts — an AFSA licence replaces the national one, and the regime to 2066 saves 20% CIT and 16% VAT.
Accounts open both inside the centre and with ordinary Kazakh banks — Halyk, Forte, BCC — while brokerage and investment banking sit with Freedom. Compliance tests the business model and source of funds as strictly as for any Kazakh company.
Who the centre works for
Managers and funds. At the end of 2025 the centre counted 159 investment funds and 68 licensed managers, with AUM above $3 billion. The fund framework covers exempt and non-exempt funds, and an AIX listing opens local retail — 2.3 million brokerage accounts.
Family offices. The Family Offices Framework has applied since 1 July 2024: a single family office is set up in the centre and launches SFO Funds, with a lighter regime for the SFO Fund Manager reflecting the closed investor base. For Central Asian families this is the nearest way to hold assets under common law.
Holdings. An AIFC company sits above Kazakh operating assets with a listing in view: AIX has raised $473 million in equity and $10.5 billion in debt, and individual shareholders take the PIT exemption on listed securities.
For individuals the centre offers the Investment Tax Residency Programme: an investment from $60,000 into AIX securities or the capital of AIFC companies (from $150,000 into digital assets through AFSA-licensed platforms) buys a five-year investor visa for the family and Kazakh tax residency on 90 days of presence per 12 months instead of the standard 183. The economics need pricing up front: a $7,750 processing fee and an annual tax-residency charge of 7,000 MCI (about KZT 30 million in 2026), so the programme pays off on substantial foreign income. The ordinary route through Kazakh residence is an order of magnitude cheaper; the jurisdiction as a whole is assembled in the Kazakhstan guide, and routes for digital professions in creator relocation.
Practice in 2025–2026
The trajectory is steady: 1,000 companies in September 2021, 4,000 in June 2025 and 4,900+ by year end, with China, Russia, the United Kingdom, the United States, Türkiye and Singapore among the top ten countries of origin. The centre attracted $6 billion in 2025, $4 billion of it portfolio investment, while participants' tax payments over nine months rose 76% to KZT 72.8 billion. AIX turnover climbed from $1.3 to $2 billion across 200 new listings.
The enforcement mechanics have been tested in practice: AIFC Court judgments go straight into the national enforcement system, and appeals stay inside the centre — a participants' dispute never reaches the Kazakh courts. Where the dispute has no AIFC nexus the route is now contested: the Naftogaz v Gazprom recognition of May 2026 and the Justice Ministry's response are set out in the courts comparison below. The region's sanctions load has not gone anywhere, though: the presence of Russian participants and dealings with sanctioned counterparties are covered in the sanctions risk map.
The AIFC Against DIFC, ADGM, QFC and GIFT City
Five common-law enclaves compete for the same client: a manager, a fund, a family holding or a fintech that wants an English-law contract, a predictable regulator and a tax horizon longer than one parliamentary term. They divide on two things that are easy to check and one that is not — the legal source, the length of the tax promise, and how much presence has to be bought to keep it.
| Centre | Law and court | Regulator | Tax horizon | Substance demanded |
|---|---|---|---|---|
| AIFC, Astana | Its own AIFC Acts on the principles, rules and precedents of the law of England and Wales (Constitutional Statute No. 438-V); AIFC Court and the IAC, judgments enforced with no recognition step | AFSA, also the companies registrar | 0% CIT and VAT on the listed financial services to 01.01.2066, fixed at constitutional level; other income on general terms (CIT 20%, VAT 16%) | Rules on the Substantial Presence since 2022: CIGA in Astana, costs and headcount proportionate to the business |
| DIFC, Dubai | Its own DIFC laws built on common law; DIFC Courts in English, final appeal inside the centre | DFSA, with a separate Registrar of Companies | UAE federal CT 9% above AED 375,000, 0% for a Qualifying Free Zone Person on qualifying income; DMTT tops large groups to 15% from 2025 — no end date published | Office inside the DIFC; economic substance by activity |
| ADGM, Abu Dhabi | English common law applied directly, including named English statutes; ADGM Courts | FSRA, with a separate Registration Authority | Same UAE perimeter as the DIFC | Office inside ADGM; economic substance by activity |
| QFC, Doha | Its own QFC framework under Law No. 7 of 2005 on common law; QFC Civil and Commercial Court and Regulatory Tribunal | QFCRA, with the QFC Authority as licensing body | 10% on locally sourced profits, 0% for investment managers, reinsurers, captives and businesses at least 90% Qatari-owned; funds, holding structures and SPCs exempt on conditions; gains on shareholdings of 10% or more exempt; no sunset date | QFC office and the licence conditions for the activity |
| GIFT City IFSC, India | Indian law with IFSC carve-outs under the IFSCA Act 2019; no separate court — disputes go to the Indian courts or to arbitration inside the centre | IFSCA, a single unified regulator for banking, capital markets, insurance and funds | 100% deduction under s. 80LA for 10 consecutive years out of 15, MAT at 9%, no GST on services into or within the IFSC, interest to non-residents exempt, 10% on dividends to non-residents | A unit registered with IFSCA, with the activity actually carried on in the IFSC |
The second half of the comparison is what a manager or a family actually shops for.
| Centre | Family-office framework | Funds | Published cost of entry | Bank access | Sanctions perimeter |
|---|---|---|---|---|---|
| AIFC | Family Offices Framework since 01.07.2024: a single family office plus SFO Funds with a lighter regime for the SFO Fund Manager | 159 funds and 68 licensed managers at the end of 2025, AUM above $3bn; AIX listing opens local retail | Private company $500 ($1,500 on paper); licences from $7,000 for managing investments to $98,000 for a digital asset trading facility; continuation $3,000 | Accounts open both inside the centre and with ordinary Kazakh banks | Kazakhstan has imposed no measures of its own and observes Western restrictions |
| DIFC | Family Arrangements Regulations and the Family Wealth Centre | Qualified Investor, Exempt and Public Fund regimes under DFSA rules | Published per activity in the DIFC handbooks | UAE banks plus DIFC branches of global institutions — the deepest bench of the five | UAE banks screen against US and EU lists; OFAC keeps designating Emirati entities under the Russia programme |
| ADGM | ADGM Foundations and SPVs, widely used to hold family assets | Qualified Investor, Exempt and Public Fund; a heavily used fund-manager route | Private company $5,800 all in, SPV $7,800, continuance $7,500, Category B licence renewal $5,300 (Schedule of Fees 2025) | Same UAE perimeter | Same UAE perimeter |
| QFC | Holding structures and SPCs, exempt on conditions | QFC funds regime under QFCRA rules | Published by the QFC Authority per activity | Qatari banks; no published non-resident policy | Qatar applies UN measures |
| GIFT City | Family Investment Fund under the IFSCA Fund Management Regulations | Fund Management Entity regime covering retail, restricted and authorised schemes | Published in the IFSCA fee schedules per activity | IFSC Banking Units of Indian and foreign banks | India applies UN measures and has imposed no unilateral measures |
Reading the two tables
The legal source separates ADGM from everyone else. Abu Dhabi applies English common law directly, named statutes included, so a contract drafted for London needs almost no translation. The AIFC, the DIFC and the QFC each wrote their own statute book on common-law principles, which is close but not identical — the gap shows up in unusual instruments and in the case law available to argue from. GIFT City is the outlier: the law is Indian, the carve-outs are statutory, and there is no dedicated court, so the forum question has to be answered by an arbitration clause rather than by geography.
The tax horizon is where the AIFC is strongest and the comparison least appreciated. Article 6 of the Constitutional Statute runs to 1 January 2066 and sits at constitutional level, so ordinary legislation cannot repeal it — the 2026 tax reform raised the general rates and left the centre untouched. GIFT City promises 10 years out of 15 and a sunset that has already been extended once. The QFC has no end date but starts from 10% rather than zero. The two Emirati centres now sit inside the federal corporate tax, where the zero depends on Qualifying Free Zone Person status year by year and disappears entirely for groups caught by the 15% domestic minimum top-up.
The perimeter of the relief matters more than its length. The AIFC zero attaches to a closed list of financial services; trading, manufacturing and most service revenue is taxed as it would be in any Kazakh company. The QFC starts from 10% but exempts funds, holding structures, SPCs and gains on shareholdings of 10% or more, which for a pure holding can be a better outcome than a headline zero with a narrow list. Modelling the actual income stream, not the headline, is the only way through this row.
On cost of entry the AIFC is the cheapest of the five by an order of magnitude at the registry counter — $500 against $5,800 for an ADGM private company — and that gap closes the moment a licence is involved, where the AFSA scale runs from $7,000 to $98,000. Substance costs converge: every one of the five now demands real activity in the jurisdiction, and the cheapest registry does not produce the cheapest year two.
What the AIFC does not have is the DIFC's banking bench. Dubai concentrates the branches of global private banks, and for a family that needs custody, lending against a portfolio and a multi-currency account under one roof, that is decisive. Astana answers with common law, a court whose judgments enforce without a recognition step, and the longest tax promise on the table.
Which centre for which mandate
| Mandate | Centre |
|---|---|
| Regulated financial or crypto business with a Central Asian or CIS nexus, tax horizon matters | AIFC |
| Family office needing global private banking, custody and lending under one roof | DIFC |
| A fund manager who wants English common law applied literally, with SPVs above the assets | ADGM |
| A holding or captive with Gulf operations, where relief on participations beats a narrow zero | QFC |
| India-facing business, aircraft or ship leasing, an Indian investor base | GIFT City IFSC |
| Nothing regulated and no financial income | None of the five — an ordinary company in the home jurisdiction is cheaper; inside Kazakhstan that means an LLP |
Courts and Enforcement: AIFC, DIFC, ADGM, QFC, SICC and Hong Kong
The comparison above gives the court one cell. For a creditor it is the whole question: which instance is final, who may file, how a judgment reaches assets in the host state, and whether it travels further. Singapore's SICC and the Hong Kong courts are added as the two common-law benchmarks the Gulf and Astana centres are measured against; GIFT City drops out, since it has no court of its own. The choice of arbitral institution is covered separately in the forum comparison.
| Forum | Instances and finality | Who can file | Enforcement in the host state | Judgments abroad | Arbitral awards | Company register |
|---|---|---|---|---|---|---|
| AIFC Court | First instance (Small Claims up to $150,000) and Court of Appeal; appeal rulings final | Exclusive over AIFC matters; any other dispute if all parties agree | As an act of a Kazakh court, no recognition step | Kazakhstan is in neither Hague convention | IAC on site; art. 45 AIFC Arbitration Regulations recognises awards made anywhere | Public, publicreg.myafsa.com |
| DIFC Courts | First Instance, Small Claims Tribunal, Court of Appeal; CA and SCT final | DIFC matters; anyone by specific, clear and express written agreement, before or after the dispute | Dubai Courts execute without reviewing the merits, on an Arabic translation and executory formula | UAE is in neither Hague convention | DIAC since Decree No. 34 of 2021; New York Convention | Public |
| ADGM Courts | First instance (one judge) and appeal (three judges) | ADGM matters; any civil or commercial dispute the parties agree in writing to file there | Abu Dhabi enforcement judge acts without re-examining the merits, awards included | As DIFC | Recognised awards go through the same channel; New York Convention | Public; beneficial owners seen by the Registration Authority only |
| QICDRC (QFC) | First Instance Circuit and Appellate Division; appeal by permission, review not rehearing | QFC entities and matters; party accord weighed; can be named competent court for arbitration | A judgment of the courts of Qatar; own Enforcement Judge | Qatar is in neither Hague convention | Competent court under Law No. 2 of 2017; New York Convention | Public |
| SICC, Singapore | Division of the High Court; appeal to the Court of Appeal | International commercial cases under a written jurisdiction agreement; registered foreign counsel | Singapore judgment | Hague 2005 in force since 01.10.2016 | SIAC; New York Convention | ACRA BizFile |
| Hong Kong courts | First Instance, Court of Appeal, Court of Final Appeal | General jurisdiction | Domestic judgment | Mainland China under Cap. 645 since 29.01.2024 | HKIAC; New York Convention | Companies Registry search |
What the table shows
The architecture is the same everywhere: two tiers, with the last word spoken inside the centre. The difference is the bridge to the host state's bailiffs. Dubai wrote it into Law No. 2 of 2025, which replaced the 2004 statutes: the Court of Appeal is final (art. 18), parties anywhere may opt in by a specific, clear and express written agreement (art. 14(B)), and Dubai Courts execute a DIFC judgment without reviewing the merits once it carries an Arabic translation and the executory formula (art. 32). Abu Dhabi did the same in both directions in Law No. 4 of 2013 as amended in 2020 (art. 13.8 on opt-in, arts 13.15–13.16 on mutual enforcement). Qatar goes furthest in form: under art. 34 of the Court Regulations a QICDRC judgment simply is a judgment of the courts of Qatar, while appeal needs permission and runs as a review. Astana promises the most on paper — no recognition step at all.
That promise met its first hard test in 2026. On 15 May the AIFC Court recognised a Swiss-seated ICC award for Naftogaz against Gazprom under art. 45 of the AIFC Arbitration Regulations (Case No. 2 of 2026), with neither party connected to the centre. Ten days later Justice Minister Erlan Sarsembayev said Kazakhstan "will not serve as a transit venue for enforcing decisions that have no legal connection to the country" and that the ministry was drafting amendments on the recognition of foreign awards, as The Moscow Times reported. The direct-enforcement route is therefore strongest where the dispute has a real AIFC nexus and the debtor holds assets in Kazakhstan; as a conduit for unrelated awards it is now politically contested.
Outside the host state none of the four enclaves carries a judgments convention: Kazakhstan, the UAE and Qatar are parties to neither the 2005 Choice of Court Convention nor the 2019 Judgments Convention, so a judgment abroad relies on the enforcing state's own law and on bilateral treaties. Singapore has been bound by the 2005 Convention since 1 October 2016, which lets an exclusive SICC clause produce a judgment enforceable in the EU, the United Kingdom and the other contracting states. Hong Kong holds the one bridge into mainland China: Cap. 645 has applied since 29 January 2024. For assets spread across several states the arbitral award, carried by the New York Convention in all six, remains the portable instrument; recognition mechanics are set out in cross-border disputes.
The registers divide the same way in all four enclaves: the company register is public, the beneficial-owner record is not. ADGM states in terms that its record of beneficial owners is not published and is seen only by the Registration Authority.
Where the assets are, and which forum to write into the contract
| Situation | Forum |
|---|---|
| Counterparty and assets in Kazakhstan, contract tied to an AIFC participant | AIFC Court or the IAC |
| Assets in Dubai, counterparty willing to sign a clear opt-in | DIFC Courts |
| English law applied literally, assets in Abu Dhabi | ADGM Courts |
| A court judgment needed against assets in the EU or the United Kingdom | SICC under an exclusive clause |
| Assets in mainland China | Hong Kong courts or HKIAC |
| Assets in several states with no treaty cover | Arbitration seated in a New York Convention state |
Risks
The points where the AIFC regime diverges from newcomers' expectations sit in one block.
Q/A
Is the AIFC an offshore?
No. Participants remain Kazakh tax residents, the regime is assembled as BEPS/FATF-compliant, the relief attaches to a closed list of income types, and substance requirements have applied since 2022. Classic offshore anonymity is absent: the register of participants is public.
How does the AIFC Court differ from Kazakh courts?
It is independent of the national judiciary, works in English on the principles and precedents of the law of England and Wales, and is presided over by Lord Burnett of Maldon. Judgments are enforced like acts of Kazakh courts with no recognition step, and appellate rulings are final.
What does an ordinary trading company get in the AIFC?
English contract law, the court and a convenient set of corporate forms. No tax relief: trading revenue sits outside the list of financial services. For operating business a regular LLP is cheaper, and an AIFC company makes sense one level up — as a holding or ahead of a listing.
What does a crypto licence in the AIFC cost?
The application fee for Operating a Digital Asset Trading Facility is $98,000 under the fees rules in force from 1 December 2025, plus the annual supervision fee and capital for prudential requirements. FinTech Lab entry is cheaper at 30% of the standard fee, but carries sandbox limits on volumes and duration.
Did the AIFC exemptions survive the 2026 tax reform?
Yes. The exemptions are written into Article 6 of the Constitutional Statute and run to 1 January 2066; the new Tax Code did not repeal them. With general rates up (VAT 16%, CIT 20%) the gap between the centre and the general regime has become more visible.
Does the AIFC really reproduce the DIFC and ADGM model?
In the architecture, yes: its own statute book on common-law principles, an independent court, a single regulator that is also the companies registrar. In the detail, no. ADGM applies English common law directly, including named English statutes, while the AIFC wrote its own Acts on the principles and precedents of that law. The tax logic differs more sharply: the AIFC relief is written into a constitutional-level norm and runs to 2066, whereas the two Emirati centres now sit inside the federal corporate tax, where a zero depends on Qualifying Free Zone Person status renewed year by year.
Which of the five centres has the longest tax promise, and which the widest relief?
The longest is the AIFC — to 1 January 2066 under Article 6 of the Constitutional Statute, which ordinary legislation cannot repeal. The widest, for a holding, may be the QFC: it starts from 10% on locally sourced profits but exempts funds, holding structures and SPCs on conditions, and exempts gains on shareholdings of 10% or more. GIFT City promises 100% relief for 10 consecutive years out of 15, on a sunset that has already been extended. A headline rate settles nothing until the actual income stream is mapped against each centre's list.
Does an AIFC Court judgment really bypass recognition?
Inside Kazakhstan, yes: it is enforced as an act of a Kazakh court. The limit is political rather than procedural. After the court recognised a Swiss-seated award for Naftogaz against Gazprom in May 2026, with neither party connected to the centre, the Justice Minister said Kazakhstan would not act as a transit venue for decisions with no link to the country and announced amendments. A dispute with a real AIFC nexus and a debtor with Kazakh assets is the safe case.
Which of these courts produces a judgment that travels furthest?
The SICC, when the contract carries an exclusive jurisdiction clause: Singapore has been party to the 2005 Hague Choice of Court Convention since 1 October 2016, so the judgment can be enforced in the EU, the United Kingdom and the other contracting states. Hong Kong judgments reach mainland China under Cap. 645. Kazakhstan, the UAE and Qatar are in neither Hague convention, so for assets outside the host state an arbitral award under the New York Convention usually travels better than a judgment of the AIFC, DIFC, ADGM or QFC courts.