The “Tamchy” Special Financial Investment Territory: An Overview Of The Legal Framework And Institutional Structure

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The “Tamchy” Special Financial Investment Territory (hereinafter referred to as the “Tamchy” SFIT) constitutes a designated part of the Issyk-Kul Region of the Kyrgyz Republic, with boundaries determined by the President of the Kyrgyz Republic ¹ (Law of the Kyrgyz Republic No. 136 of July 10, 2025, “On the Special Financial Investment Territory “Tamchy” with a Special Legal Regime and Status,” hereinafter referred to as the Law on the “Tamchy” SFIT).

The establishment of the “Tamchy” SFIT is aimed at fostering economic development in the Kyrgyz Republic, attracting investment, improving the investment climate, and creating a competitive investment jurisdiction. This includes the development of the financial sector, infrastructure, tourism, and other industries.²

Since the adoption of the Law on the “Tamchy” SFIT, its provisions are being implemented through amendments to national legislation and the adoption of secondary legislation governing specific aspects of the territory’s functioning.

Within the system of sources of law of the Kyrgyz Republic, acts of the “Tamchy” SFIT are adopted subject to their place in the general hierarchy of normative legal acts and, in accordance with Article 6 of the Law of the Kyrgyz Republic “On Normative Legal Acts of the Kyrgyz Republic” (hereinafter the “Law on Normative Legal Acts”) ³ , rank at the lowest level within such hierarchy. At the same time, the Law on Normative Legal Acts contains special rules for resolving conflicts: in particular, pursuant to Article 32, in the event of a conflict between the provisions of a constitutional law or a code, the provisions of the Law on the “Tamchy” SFIT are applied.⁴

Legal Framework and Institutional Structure

The legal framework of the “Tamchy” SFIT consists of :⁵

international treaties to which the Kyrgyz Republic is a party;
the Constitution of the Kyrgyz Republic;
the Law on the “Tamchy” SFIT;
other normative legal acts of the Kyrgyz Republic, including acts of the “Tamchy”

A defining feature of the model is that a significant portion of regulation is carried out through acts of the “Tamchy” SFIT adopted by the Management Company. Such acts are binding on all entities within the territory of the “Tamchy” SFIT, regulate a wide range of relationships, and supplement and, in certain cases, replace general regulations. ⁶

Features of the Legal Regime

The special legal regime of the “Tamchy” SFIT is established under Article 18 of the Law on the “Tamchy” SFIT. The Management Company is empowered to adopt acts regulating, in particular:⁷

civil law relations, including relations related to participation in and/or management of entities within the “Tamchy” SFIT that are organizations;
civil procedural relations;
financial relations;
labor relations;
procurement procedures for goods, works, and services by its

At the same time, the acts of the “Tamchy” SFIT are based on the principles of English law and other common law systems, and take into account the standards of leading international financial centers. However, such acts may establish restrictions to protect the national interests of entities within the territory.

Accordingly, a key feature is that the legislature is effectively introducing elements of the common law system (Anglo-Saxon law) into the legal framework of the Kyrgyz Republic, which traditionally belongs to the civil law tradition.

It should be noted that criminal and administrative matters remain governed by the legislation of the Kyrgyz Republic. Furthermore, if an international treaty to which the Kyrgyz Republic is a party, having entered into force in accordance with the procedure established by law, establishes rules different from those provided for by the Law on the “Tamchy” SFIT, then the rules of the international treaty shall apply.

Overall, the “Tamchy” SFIT regime represents a hybrid legal model combining elements of various legal systems. On the one hand, it enhances the jurisdiction’s attractiveness to foreign investors by utilizing legal instruments familiar to them. On the other hand, the state retains control over key public law aspects of regulation.

Institutional Structure

The governing bodies of the “Tamchy” SFIT are established by law and include:⁸

The Council;
The Management Company;
The Registrar;
The Financial Regulator;
The International Dispute Resolution

These governing bodies operate independently within the scope of their authority, are not accountable to government authorities except in cases expressly provided for, and are separate legal entities in the organizational and legal form prescribed by the acts of the “Tamchy” SFIT.⁹

The Council

The Council is the supreme collegial governing body of the “Tamchy” SFIT.¹⁰ Its main powers include:¹¹

developing the main policy directions and development plans for the “Tamchy” SFIT;
managing the “Tamchy” SFIT in accordance with the best international standards for commercial and financial centers of this kind;
maintaining the status of the “Tamchy” SFIT as a leading commercial and financial center in the Commonwealth of Independent States and Central Asia;
providing all necessary infrastructure, personnel, services, and other support to achieve its objectives;
controlling the execution of an annual budget of the “Tamchy” SFIT;
spending the funds received at its discretion to perform its functions, tasks, and exercise its powers, including providing the necessary funding to management bodies;
establishing internal procedures;
exercising other powers and fulfilling obligations necessary to achieve the objectives of the “Tamchy”

The procedure for the formation and operation of the Council is detailed in Resolution No. 609 of the Cabinet of Ministers of the Kyrgyz Republic dated September 24, 2025, according to which the Council performs the functions of strategic management and control, ensuring a balance between the interests of the state and investors.

The Management Company

The Management Company is a key executive body. Its powers include:

general management of the territory,
adoption of acts of the “Tamchy” SFIT,
licensing the activities of entities,
setting fees and tariffs,
infrastructure development,
administration of the access control regime, and
other powers provided for by

Within the framework of the subordinate regulation, the Management Company also plays a central role in matters of:

migration registration;
visa processing;
interaction with government

Financial Regulator

The financial regulator regulates, licenses and supervises the financial sector, as well as activities related to virtual assets. At the same time, it operates independently from the National Bank of the Kyrgyz Republic.

It should be noted that the Law on the “Tamchy” SFIT allows for the creation of financial institutions, including banks, exchanges, and crypto infrastructure.

International Dispute Resolution Center

The International Dispute Resolution Center protects the rights and legitimate interests of the parties to disputes under its jurisdiction and ensures compliance with the Law on the “Tamchy” SFIT, the acts of the “Tamchy” SFIT and other regulatory legal acts to be applied in resolving relevant disputes. The International Dispute Resolution Center sets its own fees and tariffs.

In addition, this Center is an independent body. ¹²

In view of the above, it should be noted that this Center: ¹³

is not part of the judicial system of the Kyrgyz Republic;
applies the norms and principles of English law;
handles civil and commercial

It is important to note that the International Dispute Resolution Center includes two structures:

The Dispute Resolution Committee (hereinafter referred to as the Committee);
Arbitration Center, including the center for alternative dispute

The Committee consists of two instances: a first-instance committee, which includes the committee on minor cases, and the appeals committee. The decisions of the Appeal Committee are final and are not subject to review, supervision or appeal in any other court of the Kyrgyz Republic. The Committee's decisions are binding on all individuals and legal entities.

There is currently no more detailed information on the scope of the powers and regulation of the Arbitration Center's activities. We believe that the relevant regulatory legal acts are in the process of being developed.

Regulatory and administrative features

As part of the implementation of the Law on the “Tamchy” SFIT, by-laws have been adopted that form a practical model for the functioning of the territory (see Applicable Legislation).

Resolution No. 118 of the Cabinet of Ministers of the Kyrgyz Republic dated February 18, 2026 established:

Checkpoint regime;
The order of operation of the checkpoint;
Rules for the movement of persons, vehicles, and

In particular:

Specialized checkpoints (road, air, shore) are in operation;
Migration registration system is in place;
There is a special procedure for interaction between government authorities and the Management

A separate entry mode is provided through Issyk-Kul International Airport based on the transit zone principle, in which:

movement is allowed without going through standard control procedures;
it is possible to stay in the territory of the “Tamchy” SFIT without a visa for up to 96 hours;
a person is not deemed to have entered the territory of the Kyrgyz Republic before passing the

Tax, customs and currency regimes

Taxation

There is a special tax regime in force on the territory of the “Tamchy” SFIT, provided for by both the Law on the “Tamchy” SFIT and Chapter 64 of the Tax Code of the Kyrgyz Republic.

According to Article 465 of the Tax Code, this regime applies exclusively to the activities of entities of the “Tamc¹⁴ SFIT carried out in accordance with the legislation on the “Tamchy” SFIT. At the same time, the activities of such entities outside the territory of the “Tamchy” SFIT are subject to taxation on a general basis.

Individuals and legal entities, including foreign ones, registered¹⁵ in the specified territory are recognized as entities of the “Tamchy” SFIT.¹⁶

The key features of the regime are as follows:

the activities of the entities of the “Tamchy” SFIT that meet the established requirements are exempt from all taxes, unless otherwise provided by the Tax Code or the Law on the "Tamchy" SFIT;
tax obligations arise when carrying out activities outside of the “Tamchy” SFIT;
obligations on state social insuraceare¹⁷ maintained in accordance with the legislation of the Kyrgyz

Thus, the tax regime of the “Tamchy” SFIT is territorially limited and applies only to activities within the “Tamchy” SFIT.

Customs regulation

The “Tamchy” SFIT customs regime is formed on the basis of a combination of the provisions of the Law on the “Tamchy” SFIT, the Tax Code and the law of the Eurasian Economic Union (hereinafter referred to as the "EAEU").

According to the Law: ¹⁸

The “Tamchy” SFIT is part of the customs territory of the EAEU;
A free customs zone regime is applied on its

The provisions of the Tax Code complement this regime by establishing that: ¹⁹

the administration of taxes on the movement of goods across the border of the “Tamchy” SFIT is carried out in accordance with the law of the EAEU and the legislation of the Kyrgyz Republic in the field of customs;
when goods are exported from the territory of the “Tamchy” SFIT to the rest of the Kyrgyz Republic, general tax legislation is

By-law regulation (Resolution No. 118 of the Cabinet of Ministers of the Kyrgyz Republic dated February 18, 2026) additionally establishes:

the checkpoint system;
the order of movement of goods;
application of free customs zone

Thereby, the “Tamchy” SFIT customs regime is a special model in which preferential treatment within the territory is combined with the application of general regulation in interaction with the rest of the territory of the Kyrgyz Republic and the EAEU.

Currency regulation

The special currency regime provides for the free circulation of foreign currency and virtual assets, as well as the freedom to choose the settlement currency by agreement of the parties.²⁰

Visa and migration regimes

The Law on the “Tamchy” SFIT establishes a special visa regime, which is implemented through secondary legislation. ²¹

Special categories of the “Tamchy” visas have been introduced, including:

Investment, business and work visas;
visas for residents and their family members;
internal visas for staying exclusively on the territory of the “Tamchy”

Key features of the mode:

the duration of visas is up to 5 years;
simplified extension;
separate entry, stay and exit

The above-mentioned visas are issued by the authorized state body responsible for visa issuance on the basis of an application submitted by the Management Company of the “Tamchy” SFIT through the “Electronic Visa” portal available on the official website.

In addition, it is allowed to attract foreign labor without obtaining permits.²²

Permitted activities

The Law provides for a wide range of permitted activities, including: ²³

Financial, banking and investment activities;
Activities in the capital and virtual asset markets;
Asset and fund management;
Insurance and reinsurance;
Professional services;
Tourism and medical activities; and
other types of activities provided for by the specified

At the same time, a list of prohibited activities has been established, including mining, trafficking in weapons, narcotic drugs, as well as the production of certain types of products.

Infrastructure and environmental requirements

Resolution No. 800 of the Cabinet of Ministers of the Kyrgyz Republic dated December 11, 2025 established mandatory requirements for the development of the “Tamchy” SFIT territory.²⁴

These requirements include:

compliance with environmental standards;
preservation of the ecosystem of Lake Issyk-Kul;
infrastructure and zoning requirements;
mandatory environmental impact assessment;
control over the use of natural

Therefore, the development of the territory is accompanied by significant environmental and infrastructural requirements.

Potential legal risks

Despite the preferences provided, when operating with “Tamchy” SFIT, you should take into account:

lack of established law enforcement practice;
possible conflicts with national legislation and the law of the EAEU;
features of recognition and execution of decisions of the “Tamchy” SFIT

The “Tamchy” SFIT is a comprehensive legal regime combining elements of autonomous regulation, institutional independence, tax, customs and currency incentives, as well as a specialized dispute resolution system.

The emerging model is aimed at creating an investment jurisdiction in the Kyrgyz Republic with the characteristics of an international financial center. Its practical effectiveness will depend on the further development of secondary legislation and the formation of sustainable law enforcement practices.

Applicable Legislation:

The Law of the Kyrgyz Republic "On the Tamchy Special Financial Investment Territory with a special legal regime and status";
The Law of the Kyrgyz Republic "On Regulatory Legal Acts of the Kyrgyz Republic";
The Tax Code of the Kyrgyz Republic;
The EAEU Customs Code;
Resolution of the Cabinet of Ministers of the Kyrgyz Republic "On Approval of the Requirements for the Development of the “Tamchy” Special Financial Investment Territory with a Special Legal Regime and Status" dated December 11, 2025 800;
Resolution of the Cabinet of Ministers of the Kyrgyz Republic 118 dated February 18, 2026 "On approval of the Procedure for ensuring the checkpoint regime, issuing special categories of visas and establishing requirements for staying in the “Tamchy” Special Financial Investment Territory".

Footnotes

^{1. The Law of the Kyrgyz Republic dated July 10, 2025 136 "On the special financial investment territory "Tamchy" with a special legal regime and status", Article 1, URL: https://cbd.minjust.gov.kg/4-5573/edition/34554/ru}

^{2. Article 5}

^{3. The Law of the Kyrgyz Republic dated July 20, 2009 241 "on Regulatory legal acts of the Kyrgyz Republic", URL: https://cbd.minjust.gov.kg/4-3987/edition/1086595/ru}

^{4. Ibid}

^{5 The Law of the Kyrgyz Republic dated July 10, 2025 136 "On the special financial investment territory "Tamchy" with a special legal regime and status", Article 1, URL: https://cbd.minjust.gov.kg/4-5573/edition/34554/ru}

^{6 Article 15}

^{7 Article 17}

^{8 Article 6}

^{9 bid.}

^{10 Article 7}

^{11 Article 8}

^{12 Article 14}

^{13 Ibid.}

^{14 Tax Code of the Kyrgyz Republic 3 dated January 18, 2022, URL: https://cbd.minjust.gov.kg/3-39/edition/1286442/ru}

^{15 Article 466}

^{16 Article 467}

^{17 The Law of the Kyrgyz Republic dated July 10, 2025 136 "On the special financial investment territory "Tamchy" with a special legal regime and status", Article 19, URL: https://cbd.minjust.gov.kg/4-5573/edition/34554/ru}

^{18 Article 20}

^{19 Tax Code of the Kyrgyz Republic 3 dated January 18, 2022, Article 467, URL: https://cbd.minjust.gov.kg/3-39/edition/1286442/ru}

^{20 The Law of the Kyrgyz Republic dated July 10, 2025 136 "On the special financial investment territory "Tamchy" with a special legal regime and status", Article 21, URL: https://cbd.minjust.gov.kg/4-5573/edition/34554/ru}

^{21 The Law of the Kyrgyz Republic dated July 10, 2025 136 "On the special financial investment territory "Tamchy" with a special legal regime and status", Article 22 URL: https://cbd.minjust.gov.kg/4-5573/edition/34554/ru}

^{22 Article 23}

^{23 Article 16}

^{24 Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated December 11, 2025 800 "On Approval of the Requirements for the Development of the Tamchy Special Financial Investment Territory with a Special Legal Regime and Status, URL: https://cbd.minjust.gov.kg/7-49615/edition/44578/ru}

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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