Special Financial Investment Territory “Tamchy”: Overview of Recent Changes
Updated: August 19, 2026
In Brief
The Tamchy Special Financial Investment Territory (the “Tamchy SFIT”) is a territory with a special legal regime and status located on the shore of Lake Issyk-Kul, established by Law of the Kyrgyz Republic No. 136 “On the Tamchy Special Financial Investment Territory with a Special Legal Regime and Status” (“Law No. 136”) dated 10 July 2025. Covering 5,964.73 hectares in the Issyk-Kul district of Issyk-Kul region, the territory operates under a distinct set of rules: a 49-year exemption from all taxes for its subjects, a free customs zone regime, free circulation of foreign currency and virtual assets, a simplified visa regime, and a legal system based on the norms and principles of English law. This makes the Tamchy SFIT one of the few investment jurisdictions in Central Asia offering long-term tax incentives for investors.
On 3 July 2026, the Tamchy SFIT was officially launched, and the first foreign resident investors received their certificates. According to the Ministry of Economy and Commerce, the project aims to attract approximately USD 20 billion in investment and create around 10,000 jobs, primarily for Kyrgyz citizens, by 2031. Tamchy SFIT management estimates that companies could see operating and regulatory costs fall by up to 60% compared with other international financial and investment jurisdictions.
For an investor, financial institution, or technology company, this is the first platform in Kyrgyzstan where applicable law, the tax regime, dispute resolution procedures, and staff entry arrangements have been designed to meet the expectations of international business.
What the Tamchy SFIT Is and Why It Was Created
The key difference between the Tamchy SFIT and conventional free economic zones is that its regime is not limited to tax and customs preferences. Law No. 136 establishes a territory with its own system of governing bodies, its own financial regulator, registrar and dispute resolution center, as well as a self-contained body of regulations based on the norms and principles of English law.
Under Article 5 of Law No. 136, the territory was established to develop the economy of the Kyrgyz Republic, improve the investment climate and attract investment, guarantee the protection of the rights and legitimate interests of investors (including foreign investors), and support the creation and development of production, transport infrastructure, tourism, and health resort facilities.
Any commercial activity is permitted within the Tamchy SFIT except where expressly prohibited by law. Prohibited activities include, in particular:
- production of fuel and lubricants, alcoholic beverages and tobacco products
- mineral exploration and extraction
- production, repair and sale of weapons, ammunition and explosives
- trafficking in narcotic and psychotropic substances
- operations involving radioactive, nuclear and other hazardous materials
Who May Become a Tamchy SFIT Subject
To operate within the territory and access its benefits, an entity must hold the status of a Tamchy SFIT subject. This status is available to individuals and legal entities, including foreign persons, that are duly registered and, where required, licensed for the relevant activity.
Law No. 136 expressly prohibits interference by state authorities and local self-government bodies in the operations of the Tamchy SFIT and its subjects. The legal forms available to entities and the terms of operation for individuals are set out in separate acts adopted by the Tamchy SFIT, rather than under the Civil Code of the Kyrgyz Republic in its ordinary application. For corporate groups, this makes early structuring of ownership and contractual relationships between the SFIT subject and other group companies essential.
Territory and Governing Bodies
The boundaries of the Tamchy SFIT were established by Presidential Decree No. 305 of 7 November 2025: the territory comprises four land plots within the Shaiybek Ata and Toru-Aigyr-Tamchy ayil aimaks, with a total area of 5,964.73 hectares.
Law No. 136 provides for the following principal governing bodies:
| Body | Functions |
|---|---|
| Governing Council | The supreme collegial body: development strategy and plans, overall governance, oversight of the budget and the Managing Company, and appointment of the Managing Company’s head, the Chair of the ICDR, and judges |
| Managing Company (MC) | Day-to-day administration, rule-making, licensing, budgeting, and setting fees and tariffs |
| International Center for Dispute Resolution (ICDR) | Dispute resolution and interpretation of Law No. 136 and Tamchy SFIT acts |
| Registrar | Registration of Tamchy SFIT subjects |
| Financial Regulator | Regulation, licensing and supervision of the financial market |
Formally, Law No. 136 identifies only the Governing Council as the supreme body. Its formation and operating procedure are set out in Law No. 136 and Cabinet of Ministers Resolution No. 609 of 24 September 2025. The Council consists of a Chair and nine members, including the head of the Managing Company; members are appointed for five-year terms with unlimited possibility of renewal, and a quorum requires five members.
In practice, the greatest share of authority rests with the Managing Company, which combines executive and rule-making functions. The Financial Regulator effectively combines the functions of a national bank and a financial market supervision authority, providing a single window for regulation and licensing.
Dispute Resolution: The ICDR (International Center for Dispute Resolution )
The ICDR comprises a Dispute Resolution Committee (with first-instance and appellate panels) and an arbitration center, including an alternative dispute resolution center. The Center holds exclusive jurisdiction over civil and commercial disputes, excluding criminal and administrative matters. Foreign nationals may serve as judges and as Chair of the Committee, and the Committee must have at least six members.
Decisions of the appellate committee are final and are not subject to review or appeal before any other court of the Kyrgyz Republic; the Committee’s judgments are enforceable throughout the Kyrgyz Republic on the basis of writs of execution it issues.
Notably, the ICDR may also hear disputes between parties that are neither registered with, nor conducting business within, the Tamchy SFIT, provided the parties have agreed to submit the dispute to its jurisdiction. This allows an ICDR arbitration clause to be used in contracts unrelated to the Tamchy SFIT itself.
Legal Regime
Under Article 2 of Law No. 136, the legal basis for the Tamchy SFIT’s operations comprises the Constitution of the Kyrgyz Republic, Law No. 136, other regulatory legal acts of the Kyrgyz Republic, and applicable international treaties.
Law No. 137, adopted alongside Law No. 136 on 10 July 2025, amends a number of legislative acts (the Land, Civil, Civil Procedure and Labor Codes, the Tax Code, and laws on banking activity, the securities market, virtual assets, external migration, and others). Under these amendments:
- the laws “On the Securities Market,” “On Virtual Assets,” and “On Banks and Banking Activity” do not apply to financial institutions within the Tamchy SFIT
- licensing of subjects is governed by Law No. 136
- subjects benefit from a special tax regime exempting them from all taxes for 49 years
- other codes and laws apply only to the extent not otherwise regulated by, or in conflict with, Law No. 136
- in the event of a conflict, Law No. 136 prevails
- Tamchy SFIT acts are classified as regulatory legal acts
Acts of the Tamchy SFIT are adopted by the Managing Company and must be based on the principles of English law and the standards of leading global financial centers. English law is valued for its flexibility, while resting on stable principles that are familiar and predictable to foreign investors: the rule of law, freedom and binding force of contract, good faith between parties, and compensatory liability. This provides a reliable foundation for enhancing the territory’s attractiveness to investors.
Tax Incentives
The central benefit of the regime is the exemption of subjects from all taxes for a period of 49 years from the date Law No. 136 entered into force.
This tax exemption does not mean an absence of payments altogether. As noted by the Ministry of Economy and Commerce, alongside the incentives, special charges apply that fund the Managing Company’s revenue, with a portion directed to the national budget. Accordingly, financial modeling of any project should factor in the aggregate burden, including fees, tariffs, licensing charges, and the tax consequences of operations conducted outside the Tamchy SFIT perimeter.
Currency, Customs and Visa Regime
Law No. 136 provides for a free customs zone procedure across the entire territory, free circulation of foreign currency and virtual assets, a simplified entry and exit regime with five-year visas issued to foreign employees and their family members, and the ability to hire foreign employees without work permits.
Cabinet of Ministers Resolution No. 118 of 18 February 2026 approved a procedure establishing dedicated checkpoints at the territory’s border, their integration with the Unified System for Recording External Migration, a dual-gate system at Issyk-Kul International Airport, special “Tamchy” visa categories, and visa-free stays of up to 96 hours for travelers arriving through the airport’s transit zone. Together, these measures address three typical operational needs of cross-border business: the movement of capital, personnel, and goods.
Opportunities for Investors
The Tamchy SFIT was officially launched on 3 July 2026, and registration of subjects is now open. Key targets set by the Ministry of Economy and Commerce include attracting approximately USD 20 billion in investment by 2031, creating around 10,000 jobs, and reducing company costs by up to 60%.
The territory’s regime is best suited to financial institutions and fintech ventures, management companies and funds, insurance and brokerage firms, IT companies, and projects in tourism, hospitality, and logistics. In effect, the Tamchy SFIT functions as a next-generation special economic zone for Kyrgyzstan — offering a broader set of incentives than classic free economic zones.
Risks and Open Questions
A significant portion of the regulatory framework is still being developed. The legal forms, operating conditions, and licensing requirements for subjects are determined by acts adopted by the Managing Company, meaning investors must operate within a partially incomplete legal framework. The project’s success will depend on the quality of its implementation — in particular, whether Tamchy SFIT acts genuinely reflect the principles of English law, and on the professionalism, predictability, and independence of its governing bodies. Further analysis is warranted on the interaction with “mainland” law, the overall tax burden (including special charges), the concentration of authority within the Managing Company, and compliance with international anti-money laundering standards.
Baker Tilly Bishkek Legal’s Assessment
The Tamchy SFIT is a project without precedent in the region: it has its own territory, a quasi-governmental management structure, a special legal regime, and its own “population” in the form of registered subjects. Kyrgyzstan is offering a combination rarely seen in the region — long-term tax and customs relief, flexible currency arrangements, simplified visa and migration regimes, a dedicated financial regulator, and an internationally oriented dispute resolution system.
In our assessment, this makes the territory particularly attractive to financial institutions and fintech ventures, though the same combination of features may also appeal to other categories of investors. The project’s future development will depend on the quality of its substance and execution. Businesses considering the Tamchy SFIT are advised not to delay legal and tax analysis: early entry offers advantages but requires more careful deal structuring and risk management.
Frequently Asked Questions
What is the Tamchy SFIT?
A special financial investment territory with a special legal regime, established under Law No. 136 of 10 July 2025. Located on the shore of Lake Issyk-Kul, it covers 5,964.73 hectares and was officially launched on 3 July 2026.
What incentives are available to subjects?
Exemption from all taxes for 49 years, a free customs zone regime, free circulation of currency and virtual assets, a simplified visa regime, the ability to hire foreign nationals without work permits, and a legal regime based on English law. Special charges, fees and tariffs continue to apply.
Who can become a Tamchy SFIT subject?
Individuals and legal entities, including foreign persons, that are registered within the territory and, where required, licensed.
What governing bodies does the Tamchy SFIT have?
The Governing Council, the Managing Company, the ICDR, the Registrar, and the Financial Regulator.
Why might the Tamchy SFIT appeal to investors?
Because of its combination of a long-term tax regime, a free customs zone, free currency circulation, simplified entry for personnel, and a legal system based on English law. According to its organizers, company costs may fall by up to 60%.
Has company registration begun?
Yes. The territory was launched on 3 July 2026, and registration is carried out by the Tamchy SFIT Registrar.
How does the Tamchy SFIT differ from special economic zones?
Unlike classic SEZs, the Tamchy SFIT regime is not limited to tax and customs incentives: the territory has its own system of governing bodies, its own financial regulator, registrar, and dispute resolution center, and its regulatory framework is built on the principles of English law.
About the Authors
This material was prepared by the law firm Baker Tilly Bishkek Legal together with the International Business Council (IBC), with the aim of informing the business community about the legal regime and investment opportunities of the Tamchy SFIT.
Baker Tilly Bishkek Legal is a member of the international Baker Tilly network and provides services in investment support, corporate law, tax consulting, public-private partnerships, banking and project finance, and dispute resolution, as well as comprehensive market-entry guidance for the Kyrgyz Republic.
This material is for informational purposes only and does not constitute legal advice.
🔗 The full article is available in the attached document: Special Financial Investment Territory “Tamchy”