When it comes to taxes, the law not only requires but also protects. Every taxpayer has a clear list of rights, opportunities, and responsibilities that make relations with the government transparent and predictable.

Your rights
The main rule: you are not alone in the system. You have the right to information and support.

• The right to know and receive clarification. You can always contact the tax service and receive up-to-date information on taxes, rates, and the latest legal changes. If you have a specific situation, you are obligated to receive clarification. Large businesses participating in a special program (horizontal monitoring) have an additional option: a preliminary assessment by a government agency regarding planned transactions.
• Right to representation. It's not necessary to personally attend legal proceedings. Your interests can be represented by a legal representative (for example, a parent for a child) or an authorized person with a power of attorney. However, having an assistant does not deprive you of the right to act independently.
• The right to protection and justice. If you disagree with the tax authorities' decision, actions, or inaction, you can and should appeal. You also have the right to request a change in tax payment deadlines (for example, an installment plan), if there are legal grounds for doing so. And remember: you are not obligated to provide the tax authorities with documents that are not related to taxes.
• Right to an audit. To ensure the accuracy of your calculations, you can hire independent auditors to verify them.

Responsibilities are the flip side of rights.
Their essence is simple: honesty and timeliness.

• The main rule: taxes must be paid on time and in full. That's the foundation.

• Interacting with the auditors. If the tax authorities request documents as required by law, you must provide them. And if you conducted an independent tax audit, be prepared to show both the contract with the auditors and their report.
• Special Liability. If your property has been subject to restrictions (such as a lien), you are obligated to maintain it until the lien is lifted. Only normal wear and tear is taken into account.
• Rules for businesses with cash registers. For those handling cash, there are additional requirements:
• Observe all rules for using the cash register.
• Keep cash documents (books, receipts, reports) for the entire statute of limitations.
• In some cases, undergo biometric identification.

Information for buyers: taxpayer passport
There's a separate rule for food service and retail establishments that benefits us all. They are required to display a so-called taxpayer passport in a prominent location (for example, near the cash register). This isn't a secret document, but rather public information about the company, encrypted in a QR code (barcode). Any customer can scan it and learn basic information about the seller. This is done for business transparency.

How are your rights protected?
The state guarantees the protection of your interests. And here's an important prohibition: the tax authorities and their employees have no right to demand anything from you that isn't provided for by law. No "invented" obligations. If your rights are violated, you can seek protection in accordance with the procedure established by law.

When someone else acts for you
The law divides representatives into two types.

• Legal representatives. These are those who represent a person's interests by law (parents, guardians). Their actions are automatically considered the actions of the person themselves.
• Authorized representatives. Those to whom you have consciously entrusted your affairs. For an individual, this is a notarized power of attorney; for a company, this is a power of attorney or incorporation documents. These days, you can also appoint a representative online, through your taxpayer account.

An important detail: if a representative acts on your behalf, the tax authorities consider it the same as if you were acting on your own, with all the ensuing consequences.

Special case: subsoil users and operatorsFor large subsoil use projects (for example, when several companies join together to develop a deposit), the law allows for the possibility of conducting business through an operator. This is a company that represents all participants. The operator has the same rights and obligations as a regular taxpayer. And if the operator acts on behalf of the participants, this is considered the actions of both the operator and those it represents.

Official status
The State Revenue Committee operates as a national government agency under the jurisdiction of the Ministry of Finance of the Republic of Kazakhstan. Within its established purview, the Committee implements regulatory, supervisory, and executive functions.
Legal attributes:

• the presence of an official seal with the name in the state language;
• own documentation forms;
• treasury accounts;
• the right to act as a party to legal relations on one's own behalf.

Financial support
The structure’s activities are financed exclusively from the republican budget.
Important limitation

• The Committee is legally prohibited from entering into contractual relationships with business entities on matters within its direct responsibilities. In cases where the law permits income-generating activities, the proceeds are to be transferred to the state budget.

Key areas of work

Tax block

Direction	Content
Control compliance legislation	Supervision of compliance with tax regulations
Security receipts	Monitoring the completeness and timeliness of payment of taxes and mandatory payments
Social deductions	Control over the calculation and transfer of social payments
Tax policy	Participation in the development and implementation of the state tax strategy

Customs block

Direction	Content
Legislation of the EAEU	Ensuring compliance with the Union's customs regulations
Protective measures	Control of special, anti-dumping and countervailing duties
Safety	Protecting the health of citizens, the environment, and flora and fauna
Simplification procedures	Creating conditions for accelerated movement of goods across the border
Traceability	Coordination of mechanisms for tracking imported goods

Regulation of the excise market
The State Revenue Committee controls the entire circulation cycle:

• ethyl alcohol;
• alcoholic beverages;
• tobacco products;
• petroleum products and biofuels.

Additional spheres

• Rehabilitation and bankruptcy (except for the financial sector);

• International tax cooperation;

• Development of IT infrastructure for taxpayers;
• Ensuring the availability of electronic government services.

Authority and boundaries of responsibility
Control tools

Tool	Description
International exchange	Interaction with foreign tax authorities
Access to accounts systems	The right to request access to accounting software
Request documentation	Request for primary documents and accounting registers
Receipt explanations	Request for written clarifications on reporting
Banking information	Request for account information and cash flow (within the law)
Withdrawal materials	Forced seizure of documents in case of violations
Development systems	Creation and operation of information resources
Scientific activity	Research, teaching, publishing

Pilot projects
The Committee has the right to initiate and implement experimental taxation and administration regimes for the subsequent scaling up of successful practices.

Management architecture
Structural divisions of the central office

Subdivision	Functional
Department of Human Resources and Finance	Staff support and financial planning
Department analytics and risks	Data processing, statistics, risk management
Department digitalization and services	Electronic services and digital transformation
Department of IT Infrastructure	Technical support of information systems
Department of Tax Methodology	Development of approaches to taxation
Department of Customs Methodology	Formation of customs procedures
Control Department	Conducting control activities
Audit Department	Audit checks
Department of Operational Control	Ongoing monitoring of compliance with standards

Independent management

• Protection of state secrets and mobilization preparation

• Legal support
• International relations
• Public communications
• Strategic planning
• Information security

Territorial network

• State Revenue Departments for Regions and Metropolitan Cities
• State Revenue Directorates in districts and cities of regional subordination

Платформа	Purpose
Official web portal	Centralized source of information, news, services
Personal account	Personalized access to data and reporting
TDS TP	Tax Document Submission system for Taxpayers
Astana-1	Comprehensive system for customs administration
EI	Working with electronic invoices
Excise	Monitoring the turnover of excisable goods

Main tasks:

• Monitor compliance with tax legislation.
• Participate in the implementation of the country's tax policy.
• Ensure economic security.
• Develop electronic services to make it convenient for taxpayers to communicate with the government online.

The rights of the tax service: what they can do
The tax authorities have a wide range of tools to carry out their work. Here are the key ones:

• International cooperation. The tax authorities can exchange information with colleagues from other countries.
• The right to request information. They may request documents confirming the accuracy of your calculations or written clarifications regarding your reports. They also have the right to request information from banks, government agencies, and other organizations.
• Audits and controls. The tax authorities may verify the accuracy of income and property information, engage experts in audits, conduct surveys, and even take photographs and videos in cases established by law.
• Legal action. If necessary, the tax authority may file a lawsuit—for example, to invalidate a transaction, liquidate the offending company, or declare the debtor bankrupt.
• Modern technologies. They have the right to use biometric identification and certify their decisions with an electronic digital signature.

Tax Responsibilities: What They Should Do for You
The tax service has not only rights, but also clear responsibilities towards taxpayers.
The main thing is to respect your rights and protect the interests of the state.

• Inform and explain. The tax authorities are obligated to provide you with information about current taxes and changes in laws, as well as explain your obligations. Large businesses participating in horizontal monitoring are provided with preliminary clarifications on planned transactions.
• Review complaints. If you disagree with the actions of the inspectors or the results of the audit, the tax authority is obligated to review your complaint.
• Transfer materials to other authorities. If an audit uncovers administrative or criminal violations (such as tax evasion), the tax authority must transfer the materials to the appropriate authorities.
• Collecting debts. This is also a duty—to use legal means to collect tax arrears.
• Public reporting. The tax authority is required to post certain information about taxpayers on its website (e.g., debts, inactive companies, etc.), and also publish quarterly lists of major debtors in the media.

Protection of tax officials
The law also protects tax inspectors themselves. Their legal requirements are mandatory. Insults, threats, or violence against a tax inspector while on duty are punishable by law.

Tax secrecy: what's hidden and what's open
This is an important mechanism for protecting your data.
What is considered a tax secret? This is any information about a taxpayer received by the tax authorities. By default, it is not subject to disclosure.
What is not a secret (for organizations and Sole Proprietors):

• Amounts of taxes paid and accrued.

• Amounts of VAT refunded.
• The presence of tax arrears.
• Registration data (name, IIN/BIN, manager, type of activity, etc.).
• Number of employees.
• Applied fines and penalties.
• Tax incentives.

What is not a secret (for individuals):

• Amount of tax debt.
• Registration data (full name, individual identification number).
• Fines.
• Tax incentives.

Who can access your secret without your consent:

• Law enforcement agencies (upon authorization of the prosecutor or court).
• Judges (in cases where you are a party).

• Bailiffs.

• Some government agencies ( financial monitoring , national security, etc.) within the scope of their powers.
• Tax and law enforcement agencies of other countries (under international treaties).

Responsibility for disclosure
Disclosure of tax secrets or loss of documents containing such information entails liability under the law. However, the law clearly defines what is not considered disclosure (for example, transferring data to backup storage or to banks for payment processing).

The General Tax Regime (GTR) is the basic, “classical” taxation system for companies that have outgrown the small business model or operate in specific niches.
The main advantage is complete freedom from restrictions:

• Unlimited income: Your turnover can grow infinitely, without the risk of falling off the schedule.
• Unlimited Staff: Hire any number of employees.
• Any type of activity: The regime is suitable for all types of business, including those prohibited under special regimes .

The simplified tax system is applied either at the company's discretion (if the special regime is unfavorable due to a low corporate tax rate or accounting requirements) or mandatory when the business no longer meets the simplified tax system criteria. This choice favors transparency and unlimited scalability.

Corporate income tax (CIT) is a mandatory payment to the budget, calculated on a company's net profit. Simply put, it's analogous to the profit tax familiar from the tax systems of other countries.
How it works: an organization adds up all of its income for the year (sales revenue, interest on deposits, income from property rentals), subtracts from this amount all legally permitted expenses (employee salaries, raw material purchases, utility bills, office rent), and pays tax on the remaining amount—that is, on net profit.

The following are recognized as CIT payers:

• Kazakhstani companies are any resident legal entities (LLP, JSC and other forms of business) operating within the country.
• Foreign businesses are non-resident companies that have either opened a permanent representative office (branch) in Kazakhstan or simply receive income from Kazakhstani sources.

Who received the exemption?
As a general rule, state institutions are exempt from corporate income tax. However, there is an important exception: starting in 2026, state-run secondary education institutions were removed from the list of non-payers. Schools, lyceums, and gymnasiums will now pay the tax as usual.

How much to pay: rates for different types of businesses
The main change of 2026 is the transition to differentiated rates. Previously, almost everyone paid the same, but now the tax amount depends on the specific business activity of the company.

Base rate: 20%

• This is a universal rate for most companies that do not fall into special categories.

Increased rate: 25%
Payers:

• Banks (although there is a caveat: income from business lending is taxed at the standard rate, while the higher rate applies to other banking operations).
• Gambling business organizations.

Reduced rate: 3%

• For agricultural producers – companies engaged in the production of agricultural products, aquaculture products (fish farming), as well as the processing of their own harvest and the sale of processed products.

Reduced rate: 6%

• For agricultural cooperatives (except for those activities that are taxed at a rate of 3%).

Preferential transition period for the social sphere:

• 2026 – 5% for educational and healthcare organizations.
• From January 1, 2027 — 10% for the same organizations (the rate will increase, but will still remain below the base rate).

An important rule for those who have several types of activities

• If a company combines businesses that are taxed at different rates (for example, milk production and lending), it is required to maintain separate records of income and expenses for each. Otherwise, the tax authorities may recalculate everything at the maximum rate.

Advance payments: breathing easier
The rules for paying advances on corporate income tax have been significantly simplified.

• Firstly, the entry threshold was raised.

Previously, advance payments were required to be made by companies with revenues of 350,000 MCI or more. Now, this threshold has been raised to 600,000 MCI. This means thousands of small and medium-sized companies are exempt from the requirement to calculate and pay advance payments.

• Secondly, they have cancelled "fortune telling on coffee grounds".

Previously, accountants had to calculate advances themselves before filing the annual tax return, which often led to errors and overpayments. Now, the tax office calculates the amount automatically: the advance amount for the first quarter is calculated as 1/12 of the advance amount for the previous tax period. The data is already credited to taxpayers' personal accounts.

Large Business: Important Technical Details
For large business entities, the payment details have changed.
Starting in 2026, CIT from large businesses (excluding the oil sector) is credited to the republican budget under a new budget classification code — BCC 101110.

Who exactly is considered a large business entity?
According to the Entrepreneurial Code, these are companies that meet at least one of the following conditions:

• the average annual number of employees exceeds 250 people;
  
• the average annual income exceeds 3,000,000 times the MCI.
  

All other companies (medium and small businesses) must use BCC 101111 — the tax goes to the local budget.

Benefits for Socially Responsible BusinessesThe new code has seriously revised the approach to companies that employ people with disabilities. The benefits have become more targeted and strictly tied to criteria.

Who can qualify for benefits
To be eligible to reduce CIT, an organization must simultaneously meet all of the following conditions:

• Share of employees: the average annual number of employees with disabilities is at least 51% of the total workforce.
  
• Share of salary: labor costs for these employees are at least 51% of the total payroll.
  
• Share of income: at least 90% of the company's income comes from the sale of goods, works, or services produced with the participation of employees with disabilities.
  
• Employment: employees with disabilities must not simultaneously be registered with other organizations that also claim similar benefits.
  

Amount of CIT reduction

• If a company employs between 3 and 10 people with disabilities (and all the above conditions are met) — the calculated CIT is reduced by 50%.
  
• If a company employs 10 or more people with disabilities — the tax can be reduced by 100%, meaning no tax is paid at all.

Additional bonuses for such companies 
The new code also provides other preferences for organizations working with people with disabilities:

• VAT: Turnover from the sale of goods and services is exempt from VAT (subject to the same criteria for number of employees and wages).
• Social tax: Specialized organizations for persons with disabilities are exempt from paying social tax.
• Transport tax: Public associations of disabled people do not pay tax for one passenger car (up to 3000 cc) and one bus.
• Land tax: The coefficient 0 is applied (the tax is zero).
• Property tax: The rate is only 0.1% of the tax base.

Summary: What to Remember

1. CIT is a tax on a company's net profit. Taxpayers include all resident legal entities and non-residents operating in Kazakhstan.
2. Rates have changed. The base 20% remains, but now there are 25% (banks and gambling), 3% and 6% (agriculture), and 5%, with a transition to 10%, for the social sector.
3. Advance payments are easier to pay. The threshold has been raised to 600,000 MCI, and the tax office now calculates them.
4. For large businesses - new budget classification code 101110.
5. Benefits for companies with disabled employees have been tightened, but they have become more transparent. If four conditions are met, corporate income tax can be reduced by 50% or 100%, as well as exempt from VAT and other taxes.

Pay close attention to the new separate accounting rules if your business falls under different rates, and check your personal accounts for advance payments—the tax office has already calculated them for the first quarter of 2026.

Since 2026, an automated system for monitoring business fiscal discipline has been implemented in Kazakhstan. The key indicator now used by the State Revenue Committee is the individual tax burden ratio (TBR). This indicator is calculated individually for each company and sole proprietor and is compared with industry average values. If the actual TBR is lower than expected, the taxpayer automatically falls into the "red zone" — a signal for an in-depth audit.

Why this matters for income accounting: Any underestimation of total annual income (TAI) leads to an understated TBR. Even if a company has fully paid its taxes, if it incorrectly reflects the structure of receipts, the system may deem the indicators anomalous. Thus, in 2026, correctly and fully reflecting all types of income is not just an obligation, but a way to avoid excessive attention from controllers.

Below is a detailed breakdown of what economic benefits form the taxable base for enterprises operating under the general tax regime (GTR), and what risks the new administration rules entail.

Revenue from Sales — Familiar Income in a New RealityEssence: funds received from the sale of goods, performance of work, or provision of services remain the main source of TAI. The legislative definition of sales in 2026 has not changed.
What has changed in the approach?
The main feature of the current year is not how to calculate revenue, but who the counterparty is. If the buyer applies the special tax regime based on a simplified declaration (STR), then:

• For the seller (under the GTR), the revenue received is recognized as ordinary income.
  
• For the buyer under the simplified regime, the costs of purchasing goods or services from you are not deductible when calculating their taxes.
  

At first glance, there is nothing illegal. However, this asymmetry creates a risk: your counterparty has no interest in "whitening" their expenses, which may lead to the formation of "gray" chains. The tax authority, seeing a discrepancy between your income and their deductions, may suspect a tax evasion scheme. In 2026, transactions with simplified regime taxpayers require increased attention and documentary substantiation.

Positive Exchange Rate Differences — Unexpected "Paper" Income

• Essence: if a company has assets or liabilities in foreign currency (foreign currency accounts, loans, contracts), then when the official exchange rate of tenge to the currency changes, a revaluation occurs. A positive difference (when the tenge weakens and liabilities or assets in foreign currency increase in tenge equivalent) is recognized as income.
• Why this is critical in 2026: Exchange rate differences can significantly increase TAI without any actual receipt of money. For example, a company took out a loan in dollars. The tenge fell — the loan amount in tenge increased, and this difference became income. Meanwhile, there may have been no actual profit. If CIT on such "virtual" income is not paid (or is paid at a minimal rate), the TBR drops sharply. The system sees: high income on the report, but low tax — an automatic signal for an audit.
• Advice: include exchange rate differences in ongoing monitoring. They must be considered when forecasting the tax burden to avoid sharp fluctuations in the indicator.
  

Income from Disposal of Assets — When a Sale Brings More Than Just Money

• Essence: when selling fixed assets (real estate, equipment, vehicles) at a price higher than their carrying value, the positive difference is included in TAI. The procedure for determining carrying value and adjustments has largely been retained.
• Nuances for 2026: Previously, various benefits and adjustments existed that allowed reducing the taxable base (for example, the well-known 90% adjustment for wages of disabled persons, which was sometimes attempted to be applied to other transactions). 
• As of 2026, most non-systematic concessions have been eliminated. Relying on old methods to "zero out" income from the sale of an asset is no longer possible. The increase in value must be fully reflected.
  

Income from Write-off of Liabilities — Forgotten Debts Become Profit

• Essence: if a company has accounts payable (you owe someone), but the creditor has not claimed it, the statute of limitations has expired, the debt has been forgiven, or the obligation has been terminated in another way, the entire amount of the written-off debt is recognized as income.
• Example: A company owes a supplier 3 million tenge. Three years pass, the supplier has not filed a lawsuit and has not demanded repayment. The statute of limitations expires — the debt is written off, and these 3 million become subject to CIT. No money has been added to the account, but the tax base has increased. If the company does not account for this when planning payments, the TBR will be understated, and the risk of an audit will increase.
• Important: track the statute of limitations for all liabilities and assess the tax consequences of writing them off in advance.
  

Disposal of Fixed Assets — Gratuitous Transfer Is Also Taxable

• Essence: if a fixed asset is liquidated, transferred gratuitously, or disposed of in another manner that does not constitute a sale, its carrying value (within certain limits) may be included in TAI.
• This is a technical but significant point. For example, a company writes off a broken machine. Even if no money was received, the tax base increases by the residual value of the machine. Such transactions also affect the TBR, so they must be reflected correctly and promptly.
  

Summary: The Formal List Remains the Same, but Control Has Become StricterThe five main categories of income that form TAI have not changed:

• Sales.
  
• Exchange rate differences.
  
• Increase in value from the sale of assets.
  
• Write-off of accounts payable.
  
• Disposal of fixed assets.
  

However, the tax climate of 2026 is radically different from previous periods. It is no longer enough to simply declare income. It is necessary to constantly monitor two parameters:

1. Tax burden ratio. If income is reported but tax is paid at a rate below the industry average (or the tax base is reduced due to expenses that inspectors may deem unjustified), the system will automatically record a deviation.
   
2. Counterparties under special regimes. Working with simplified regime taxpayers is safe from the income side but creates problems with deductions. The same partner may be a "good" buyer but a "bad" service provider — this must be considered when planning transactions.

Rules for Adjusting IncomeSometimes initially reflected income needs to be changed (reduced or increased) due to changed circumstances. Such an adjustment is only possible on strictly defined grounds:
When income can be adjusted:

• Return of goods (partial or full).
  
• Changes in contract terms (price, volume, deadlines).
  
• Revision of the value of goods, works, services (including recalculation into tenge according to transaction terms).
  
• Provision of discounts (price discounts, sales discounts).
  

Key rule: the adjustment is made in the tax period when the basis for it arose. It is not possible to go back to a previous reporting period and correct data retroactively if the event occurred in the current period.

Summary: What Businesses Need to Do in 2026

1. Check the completeness of reflecting all five types of income — especially exchange rate differences and written-off debts, which often go unnoticed.
   
2. Analyze the impact of each income on the TBR — even "paper" receipts can distort the real picture of the tax burden.
   
3. Evaluate counterparties — working with simplified regime taxpayers is possible, but it is necessary to understand the consequences for deductions and potential tax risks.
   
4. Make adjustments in a timely manner — only when there are legal grounds and strictly in the current period.
   

In the new reality, proper income management transforms from a routine accounting task into an element of strategic tax security.

General principles for recognizing expenses when calculating corporate income tax
Before moving on to specific types of expenses—business trips, entertainment events, financial transactions, and depreciation—it's important to clearly understand the basic rules governing the deduction of the most common business expenses. These include everyday purchases: raw materials, supplies, goods for resale, and third-party labor and services. These expenses constitute the bulk of deductions for most taxpayers using the general tax regime.

Conditions under which expenses are accepted for deduction
Article 257 of the Tax Code establishes three mandatory criteria that must be met by any expenses that qualify for a reduction in total annual income:

1. Connection to income-generating activities. Expenses must be directly related to running a business and generating profit. For example, purchasing raw materials for production, paying rent for warehouse space, and transporting finished goods—all of these are clearly related to revenue generation. Personal expenses of owners or employees, as well as expenses unrelated to the business, are not deductible.
2. Actual incurrence of expenses. Expenses are considered incurred when they are documented, regardless of whether they are paid in cash or recorded as accounts payable (accrual accounting). For an expense to be recognized, it is sufficient that the obligation to the supplier arises and is properly recorded.
3. Availability of documentary evidence. A mandatory requirement is the preparation of primary accounting documents that comply with legal requirements: contracts, delivery notes, acceptance certificates for work/services, and invoices. These documents must contain all necessary details and accurately reflect the facts of business activity.

Illustration : A manufacturing company purchases components for equipment assembly. The cost of the components, as well as the services of a third-party logistics company for their delivery, are fully deductible when calculating corporate income tax. Similarly, a trading company deducts the price of the purchased goods and the cost of storing them in a rented warehouse.

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Critical Restriction of 2026: Ban on Deducting Expenses in Transactions with Simplified Tax Return (STR) Payers. On January 1, 2026, a regulation came into effect that fundamentally changes the approach to selecting counterparties. Clause 16 of Article 286 of the Tax Code states that taxpayers' expenses for the purchase of goods, works, and services from entities applying the special tax regime based on the simplified tax return (STR) are not deductible.
The practical significance of this rule:

• If your supplier operates under the general tax regime (GTR) and pays corporate income tax, their invoices (if properly completed) are accepted for deduction in full.
• If the counterparty uses a simplified tax system (STS ), then even if you have a contract, closing documents, and electronic invoices (EI), you do not have the right to reduce your taxable income by these amounts.

Why this is important: This measure is aimed at whitening the economy and preventing artificial business fragmentation schemes. For companies on the simplified tax system, this means verifying the supplier's tax status before entering into a contract. Working with a simplified tax system provider becomes unprofitable from a tax perspective: you'll incur real costs, but won't receive tax savings.

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The role of electronic invoices in confirming the right to a deduction
As a general rule, properly executed primary documents serve as the basis for a deduction. However, with the widespread digitalization of tax administration, additional VAT-related requirements arise.
If a supplier is a VAT payer and is required to issue electronic invoices (EIs), the absence of an EI registered in the information system may prevent the recognition of expenses. Tax authorities rely on data from their automated systems during audits; if an EI is not recorded, the expenses may be deemed undocumented.
Situations when the presence of an electronic invoice is not necessary:

• The counterparty is not a VAT payer and issues a paper invoice or other document confirming the transaction.
• There were technical failures, and the electronic invoice was issued on paper in the manner established by paragraph 1 of Article 492 (with subsequent mandatory entry into the system).
  

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Practical Recommendations for Businesses

1. Preliminary verification of the counterparty. Before signing a contract and transferring money, determine what tax regime the supplier operates under. If they apply the STR (special tax regime), keep in mind that these expenses will not reduce your CIT (corporate income tax), and it may be worth seeking an alternative supplier under the GTR (general tax regime).
2. Control over documentation. When working with suppliers under the GTR, require a full set of documents: a contract, a goods delivery note or work completion certificate, as well as an electronic invoice (if the supplier is required to issue one). Ensure that the EI (electronic invoice) is registered in the information system.
3. Accounting for tax consequences when planning. When calculating the expected tax burden, factor in that purchases from "simplified regime" taxpayers do not provide a tax benefit. This may influence decisions regarding supplier selection and pricing.
   
   

Understanding and complying with these basic rules is the foundation for correctly calculating CIT and minimizing the risk of claims from tax authorities under the conditions of automated monitoring of the tax burden ratio.

In 2026, special attention will be paid to so-called specialized deductions —their list has been expanded, but quantitative restrictions have been introduced for many items (percentages of the payroll, calculation formulas, etc.). Let's look at them group by group.

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Personnel and management related expenses
Employee business trips
When sending an employee on a business trip, the company has the right to deduct:

• cost of travel to the destination of the business trip and back (including reservations and transportation of baggage);
• accommodation rental costs (including reservations);
• daily allowance (the amount is determined by the employer independently, there is no legal limit);
• visa and consular fees, medical insurance costs.

Important nuances:

• Any documents, including electronic tickets, hotel bills, and receipts, are acceptable for confirmation.
• If an employee falls ill during a business trip, accommodation expenses and per diem allowances are deducted for the entire period of illness, excluding the time spent in hospital.
• Travel within one locality is not considered a business trip.
• The start and end dates of a business trip are determined by travel documents; if these are unavailable (for example, when using personal transportation), the confirmation procedure must be specified in the accounting policy.

Compensation for members of the board of directors
Travel expenses for board members (or similar bodies, other than the highest level) to perform management functions are deductible under the same conditions as business trips. The list of eligible expenses is identical: travel, accommodation, travel allowances, visas, and insurance. The basis for this deduction is an invitation or internal document confirming the location and purpose of the trip.

Entertainment expenses
These are the costs of officially receiving individuals (including those not on staff) for the purpose of establishing or maintaining cooperation, as well as holding meetings of the board of directors (except for meetings of executive bodies).
What can be included:

• transportation services for participants (except for intercity transportation);
• nutrition;
• freelance translation services;
• rental and decoration of premises for events.

Documentation is required:

• order to hold an event;
• cost estimate;
• report of the responsible person on the results;
• primary documents (checks, invoices, contracts).

Limit: entertainment expenses cannot exceed 1% of the payroll for the tax period (payroll refers to the income of employees specified in subparagraph 1) of Article 426).
What cannot be deducted:

• travel of invited persons by rail, air or water transport;

• payment for guests' accommodation;
• visa costs;

• expenses on leisure, entertainment, recreation (they are covered by net profit).

Employer's expenses for employees
All expenses related to the taxable income of employees are deductible (subparagraph 1) of Article 426), including training and professional development. However, such expenses are not deductible if they:

• included in the value of assets (fixed assets, intangible assets, inventories);
• are subsequent expenses in the control period (Article 273);
• are expressly listed in paragraph 2 of Article 270 as non-deductible.

Expenses that are not recognized as income of an individual in accordance with subparagraphs 1, 5, 7–13, 18, 20 of Article 366 (for example, compensation not subject to personal income tax) are also deducted.Financial expenses and their limitations
Interest and the Complex Deduction Formula
For the purposes of deduction, remuneration means:

• interest on debt obligations (Article 12);
• fines, penalties on loans between related parties;
• fee for a guarantee provided by a related party.

The general rule is the accrual method. However, for certain creditors, a deduction is only possible after actual payment:

• second-tier banks (except national development institutions);

• microfinance organizations (except pawnshops);
• successors in claims.

Deduction formula (Article 263, paragraph 4):

                                           (A + D) + (EC / L) × (LC) × (B + C + D')

Where:

• A — ordinary remuneration;
  
• B — remuneration to related parties;
  
• C — remuneration to persons from offshore zones;
  
• D' — remuneration secured by a deposit or guarantee of related parties;
  
• D — preferential remuneration (credit unions, UAPF, etc.);
  
• LC — limit coefficient (7 for financial organizations, 4 for others);
  
• EC — average equity capital for the period;
  
• L — average liabilities for the period.
  

If EC (equity capital) is negative, it is deemed to be zero. For permanent establishments of non-residents, equity capital is calculated as if it were a separate legal entity.

Services of non-residents from offshore zones
Expenses for management, consulting, legal, marketing, engineering, agency services, as well as royalties and intellectual property rights acquired from a related party registered in a state with preferential taxation are deductible up to 3% of taxable income before deducting these expenses.
The following are recognized as interrelated:

• persons specified in Article 14;

• companies of the same group;
• other persons by court decision.

Exchange rate differences
The net loss from exchange rate differences—the excess of negative exchange rate differences over positive exchange rate differences for the period—is deductible. This allows for losses from the revaluation of foreign currency assets and liabilities to be taken into account.

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Operations with debts and claims
Payment of previously written-off liabilities
If a liability was previously recognized as income (as doubtful or written off) and the company subsequently repaid it, this amount is deductible up to the amount of previously recognized income, minus any upward VAT adjustment (Article 485). The deduction is made in the period of actual payment.

Write-off of claims (except for questionable ones)
The following requirements are deducted:

• not claimed during liquidation of the debtor;
• written off by court decision;
• written off during the debtor's bankruptcy.

The deduction amount cannot exceed the amount previously recognized as income. The deduction period is the latest of the following dates: write-off in accounting, approval of the liquidation balance sheet, or completion of bankruptcy proceedings. This rule does not apply to doubtful claims or to the transfer of claims within a property complex.

Questionable claims
A claim that has not been satisfied within three years and arises from:

• from the sale of goods, works, services to resident legal entities, Sole Proprietors, and permanent establishments of non-residents;
• from fines and penalties based on court decisions on loans and microloans (for specialized organizations improving credit portfolios).

Who has the right to deduct?

• the original seller who did not assign the right;
• the seller who has assigned the right;
• acquirer of the right of claim;
• creditor for fines/penalties.

Deduction amount:

• for the seller - the amount of debt, not exceeding the previously recognized income;
• in case of assignment - a positive difference between the amount of the claim and the price of assignment;
• for the acquirer - the amount of debt, no more than income + acquisition price;
• for fines/penalties - the amount of recognized income.

Timeframe for the right to arise:

• for loans/leasing - from the date of payment overdue;
• for the rest - from the date of fulfillment of the obligation or from the date of transfer/assignment.

Important: Claims from banks and organizations that create provisions for certain types of debt (deposits, loans, guarantees, letters of credit) are not considered questionable. To qualify for a deduction, documentation of the claim's origin and its accounting record are required.

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Taxes and Payments to the BudgetTaxes and mandatory payments paid to the budget of the Republic of Kazakhstan or another state are deductible:

• in the current period — within the amounts accrued for the current or previous periods;
  
• in previous periods — within the amounts accrued for the current period.
  

The following are not deductible:

• taxes excluded prior to determining TAI (total annual income);
  
• CIT (corporate income tax) itself and similar taxes in other countries;
  
• taxes paid in offshore zones;
  
• excess profit tax;
  
• alternative tax for subsoil users.

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Expenditures on assets, modernization and innovation
Waste disposal sites :

• deductions to the liquidation fund, placed on a special deposit in accordance with the established procedure;
• actual costs of liquidation of landfills.

Expenses covered by the liquidation fund are not subject to re-deduction.

Scientific research, R&D, intellectual property
Expenses for research, development and technological work are deductible upon notification from the authorized science body.
Confirmation:

• for in-house developments - a report and cost documents;
• for acquired ones - technical specifications and acceptance certificates.

Exclusive rights to intellectual property acquired from universities, research organizations, or start-ups for commercialization are deducted on the basis of a registered license agreement or assignment agreement.
Funding of scientific centers at research universities entitles to a deduction upon notification from the scientific authority.

Subsequent costs (repairs, reconstruction, modernization)
Subsequent expenses include costs of operation, repair, reconstruction, modernization, and liquidation in relation to:

• fixed assets;
• assets not falling under paragraph 2 of Article 275;
• leased property;

• assets of subsoil users under Article 316 (after the start of production).

The general rule is: deduction in the period of implementation. However, a special procedure (depreciation) applies to fixed assets; for non-depreciable assets, expenses increase the original cost; and for permanent improvements to leased property, the rules for fixed assets apply.

Reconstruction/modernization are expenses that:

• change the design of the object;
• increase the useful life by more than 3 years;
• improve technical and economic performance.

Fixed Assets: A General Approach
Types of deductions for fixed assets:

• depreciation charges (Article 280);
• subsequent expenses (Article 281);

• group balance sheet value at the end of the period (Article 282).

What is included in fixed assets?

• fixed assets, real estate investments, intangible assets, biological assets (except for exceptions);
• assets of the concessionaire with a service life of more than one year;
• assets under trust management;
• inseparable improvements to leased property (except leasing);
• property of the lessor that is not accounted for as fixed assets after transfer.
  

The following are not included:

• assets of subsoil users prior to the commencement of production;
  
• assets for which depreciation is not calculated under IFRS (except concession assets, improvements, and biological assets measured at fair value);
  
• public infrastructure facilities (except concessions);
  
• fixed assets previously fully written off;
  
• intangible assets with indefinite useful lives;
  
• objects of investment preferences during the control period;
  
• depreciable assets of subsoil users under Article 316;
  
• leased assets of the lessee (except for leasing).
  

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Special case: VAT included in the price of goods
VAT payers can include the input tax in the purchase price and subsequently deduct it through depreciation or cost in three situations:

• VAT is not accepted for credit under Article 482;
• VAT is not allowed to be credited under subparagraph 2) of paragraph 2 of Article 489;
• the offset adjustment was made downwards (subparagraphs 1) and 4) of paragraph 2 of Article 484).

If VAT is not permitted for offset under Article 488 or subparagraph 3) of paragraph 2 of Article 489 and is not included in the cost of goods (works, services) in accounting, the taxpayer has the right to attribute it to deductions directly in the period in which such expenses arise.
A downward VAT adjustment is deductible if:

• the goods are used in income-generating activities, but not in VAT-taxable turnover;
• the property was transferred to the authorized capital (except for non-depreciable assets).

For non-depreciable assets, such an adjustment increases their initial cost (Articles 253–254). The rules do not apply to VAT deductible under Article 314 (subsoil users).

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Conclusion
Correctly accounting for corporate income tax deductions in 2026 requires not only knowledge of the updated regulations but also an understanding of their place in the overall tax control system. Any discrepancy—whether it's exceeding the entertainment expense limit, an error in calculating remuneration, or missing supporting documents for a business trip—will immediately impact the tax burden ratio and may trigger an audit. Therefore, we recommend:

• approve internal regulations for document flow for all types of deductions;
• conduct regular verification of the limits and formulas applied;
• track the status of counterparties (especially in cross-border transactions);
• consult with specialists on complex cases (for example, calculating the deduction of remuneration).

A well-organized system for accounting for deductions will not only reduce tax risks but also allow for the optimization of the tax burden within the law.

As of January 1, 2026, many familiar expense items have moved into the "taboo" category for deductions.

Red Zone: What Is Now Automatically Excluded from DeductionsThe updated Tax Code specifies in detail the list of costs that cannot reduce taxable income. The "stop list" includes:

• Simulation of activity. Any transactions where there is no actual supply of goods or provision of services — a formal movement of documents without a physical result. The tax authority will track chains of such transactions.
  
• Fiscal sanctions. Fines and penalties paid to the state budget no longer reduce taxable income. The only exception is for penalties under public procurement contracts.
  
• Exceeding limits. If a company exceeds the maximum deduction limit for any type of expense, the excess amount remains subject to taxation.
  
• Overpayment of taxes. Amounts paid to the budget in excess of the legally established norms of the Republic of Kazakhstan or other countries will not be deductible.
  
• Gratuitous transfers. The value of donated assets (property) — whether sponsorship or charity — now does not reduce the CIT base.
  
• VAT imbalance. The difference when input VAT exceeds output VAT for the period is not deductible.
  
• Reserve funds. Contributions "for reserves" are excluded from tax expenses.
  
• Sale of business. The carrying value of inventory upon the sale of an enterprise as a whole.
  
• Capital investments in non-depreciable property. Costs for assets that cannot be depreciated increase their value but are not written off through deductions.
  
• Ordinary rental. The transfer of assets under a lease agreement (not to be confused with leasing) does not entitle to a deduction.
  
• Non-commercial expenses. Expenses of non-profit organizations covered by targeted income.
  
• Cash settlements with VAT payers. For legal entities and sole proprietors on VAT, payment for services of individuals under civil law contracts in cash including VAT in an amount exceeding 1,000 MCI on the payment date — automatic prohibition on deduction.
  
• Maritime freight. Expenses for bareboat charters and time charters for vessels from the international register of the Republic of Kazakhstan.
  
• Film distribution. Expenses of national film rights holders for distribution and exhibition (for exclusive rights).
  
• State support for energy companies. Expenses covered by subsidies from the Government or akims, as well as grants for state enterprises in the energy sector.
  

Point of Tension: Businesses on the GTR and Simplified Regime Taxpayers Become IncompatibleAs of 2026, taxpayers on the general tax regime (GTR) lose the right to deduct expenses if goods, works, or services are acquired from persons operating under the simplified declaration (STR).
Practical meaning: Working with "simplified regime" taxpayers in B2B chains becomes a tax burden. A company on the GTR will pay money to the supplier but will not be able to reduce its CIT by that amount. This effectively creates a barrier to interaction between classic businesses and small enterprises on the special tax regime.

Domino Effect: When the Tax Authority Reassesses Past DeductionsThe new Tax Code has retroactive effect in terms of control. If a company has previously claimed certain expenses as deductions, but circumstances have now come to light, they will have to be excluded from tax accounting. The following transactions are at risk:

• With "shell companies." If a judicial act confirms that the head or founder of the counterparty was not involved in the registration and management of the firm, and the transaction was fictitious, the deduction is annulled. Exception: if the court nonetheless confirmed the actual receipt of goods/services.
  
• With inactive companies. Expenses for transactions with a company that has been recognized as inactive (from the date of such decision) are subject to exclusion from the taxable base.
  
• For falsified invoices. If the document was issued without actual supply, and this is confirmed by a court or a resolution of the internal affairs body to terminate the case on non-rehabilitating grounds.
  
• For invalid transactions. If the court declares a transaction void, all expenses related to it are reversed.
  

Summary: 2026 — The Year of Tax ResetBusinesses in Kazakhstan face not only adapting their accounting policies to the new rules but also conducting an audit of past periods for "toxic" counterparties. The choice of partners becomes particularly critical: cooperation with simplified regime taxpayers now carries not tax savings, but additional costs.

The arrival of 2026 marked the entry into force of the updated Tax Code of the Republic of Kazakhstan. This regulation not only amended the existing system but also created a fundamentally different fiscal reality. For business entities operating under the general tax regime (GTR), this means the need to revise their internal regulations governing the calculation of tax liabilities. Using accounting policies developed during the period of the previous code, which ceased to be effective on January 1, creates serious risks for businesses and prevents them from fully utilizing legal mechanisms for tax optimization. Let's examine this issue in detail.

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Reasons why the previous document became obsolete
The old Tax Code, which was in effect until 2026, and the new code (No. 214-VIII) have fundamental differences in their approaches to administration, determining the taxable object, and the procedure for recognizing expenses. Key changes that render the previous accounting policy inapplicable include:

• Complete abolition of previously existing special tax regimes and the introduction of differentiated rates for corporate income tax.
• Changes to the criteria for classifying expenses as deductions, including the introduction of prohibitions for certain types of transactions.
• Implementation of new automated control tools, such as the tax burden coefficient (TBC), which is calculated automatically and serves as an indicator for audits.
• Adjustments to the rules governing value-added tax, including changes to the thresholds for mandatory registration.

If a company's internal document contains references to articles of the previous version of the code or does not take into account the above-mentioned innovations, it cannot serve as a reliable basis for accounting and does not ensure the protection of the taxpayer's interests in the event of disputes with regulatory authorities.

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Elements That Must Be Reflected in the Updated Accounting Policy
The development of a new document is not a mechanical copying of the old text with dates replaced. It is a meticulous effort to adapt the company's internal procedures to the requirements of the updated legislation. Listed below are the key blocks that require detailed elaboration.

Organization of Separate Accounting When Combining Types of Activities
For the first time, legislation has established the mandatory requirement to maintain separate accounting of income and expenses for enterprises engaged in several types of activities that are subject to different CIT rates. Recall that in 2026, the rates vary: the base rate is 20%, for the banking and gambling sectors the rate is set at 25%, for agricultural producers — 3%, for educational and healthcare organizations — 5% with a subsequent increase to 10%. In the accounting policy, the following must be clearly specified:

• in which accounting accounts information for each activity is accumulated;
  
• how indirect expenses related to multiple types of activities are allocated;
  
• the frequency and procedure for generating data for tax reporting.

Rules for recognizing certain types of income
The updated code retains the traditional list of incomes, but the practice of accounting for them has undergone changes. The following deserve special attention:

• Exchange rate differences. In a highly volatile national currency, this type of income can have a significant impact on total annual income and, consequently, the tax burden ratio. Policy should establish the timing of recognition of such differences (at each reporting date or as transactions are completed) and the methodology for calculating them.
• Write-off of accounts payable. It is necessary to identify those responsible for monitoring statutes of limitations and the procedure for documenting debt write-offs to ensure that the corresponding amounts are reflected in income in a timely manner.
  

Fundamentally New Approaches to the Formation of Deductions
The most significant changes have affected precisely the composition of costs that reduce the taxable base. The key innovations of 2026 include:

• Prohibition on deducting expenses from transactions with STR taxpayers. Paragraph 16 of Article 286 directly states that costs for the acquisition of goods, works, or services from persons applying the special tax regime based on a simplified declaration are not deductible. This means that the accounting policy must contain an algorithm for verifying counterparties at the contract signing stage. It is necessary to establish a procedure for requesting supporting documents regarding the applicable tax regime and to determine the course of action if the supplier turns out to be a "simplified regime" taxpayer (for example, refusal of the transaction or accounting for such costs as non-deductible).
• Limitation of certain types of expenses. A number of costs are now deductible only within established limits:
  
  • entertainment expenses — not more than one percent of the payroll fund;
  • payment for services of non-residents from states with preferential taxation — within three percent of taxable income before deducting such expenses;
  • remuneration on debt obligations — using a special formula that takes into account the ratio of equity capital to liabilities.
    The accounting policy must detail the procedure for calculating these limits and the list of supporting documents (estimates, orders, reports).
    

Changes in VAT administration
Two major innovations in value added tax are associated with 2026:

• Lowering the mandatory registration threshold to 10,000 MCI. Companies whose turnover approaches this level must ensure ongoing monitoring and submit registration applications in a timely manner.
• Implementation of the e-TAMGA system, which requires a sufficient balance in a special account for issuing electronic invoices to certain categories of taxpayers.

Accounting policies must establish procedures for interaction between departments responsible for tracking turnover and liquidity management to avoid blocking transactions and imposing penalties.

Interaction with founders within the framework of general declaration
The expansion of the scope of individuals required to file income tax returns (Form 270.00) indirectly affects legal entities as well. Company founders, managers, and shareholders must report major transactions, foreign accounts, and assets. Although this obligation falls to individuals, companies should develop internal procedures for obtaining information from them that could impact the legal entity's tax liabilities (for example, information about controlled foreign companies).

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Potential threats in the absence of an up-to-date accounting policy
Ignoring the need to update the internal regulatory framework entails very specific negative consequences:

• Financial losses due to improper expense accounting. An accountant acting out of inertia and unaware of the new restrictions may deduct expenses from transactions with simplified taxation systems. During an audit, this will result in additional tax assessments, penalties, and a fine, which can reach 50% of the arrears.
• Inability to justify the application of reduced rates. If a company combines several activities but does not maintain separate accounting in accordance with the approved methodology, the tax authority has the right to recalculate tax liabilities at the maximum rate applicable to that organization.
• Operational disruptions and VAT penalties. Failure to register on time due to exceeding the turnover threshold or the inability to issue an electronic invoice due to insufficient funds in the account (under the e-TAMGA system) can paralyze business operations and result in administrative penalties.
• Automatic inclusion in the risk group. The tax burden coefficient is calculated by the State Revenue Committee's information system based on reporting data. Errors in income or expense accounting caused by the lack of clear internal regulations will lead to a distortion of the tax burden coefficient. Deviations from the industry average will trigger automatic selection of the company for audit.
• Loss of evidentiary support in disputes. Without an approved accounting policy, the taxpayer is deprived of a crucial defense. The regulatory authority will interpret any ambiguities and disputes in its favor, significantly reducing the chances of successfully appealing its decisions.

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Practical steps for developing a new accounting policy
The process of creating a current document can be represented as a sequence of actions:
1. Initial diagnostics. It is necessary to conduct a comprehensive analysis of the company's current operations: identify all activities, its revenue structure, key suppliers (identifying their tax regimes), and assess its approach to the VAT threshold.
2. Project development. Based on the data obtained, the text of the document is compiled. It should include:

• general provisions and scope of application;
• methods of accounting for income and expenses, taking into account all legislative innovations;
• procedure for maintaining separate records (if necessary);

l  regulations for checking counterparties;
l  VAT document flow rules;

• approved forms of internal primary documents (orders on business trips, estimates of entertainment expenses, reports, etc.);
• appointment of persons responsible for compliance with certain provisions.

3. Expert assessment. It is advisable to engage a tax consultant or auditor to review the draft document to ensure it complies with the provisions of the new code.
4. Official approval. The document is put into effect by order of the manager. It is optimal to set the effective date of January 1, 2026, to extend its application to all transactions during the reporting period.
5. Informing staff. All employees involved in tax reporting or interacting with contractors, including accountants, economists, and procurement staff, must be familiar with the policy. Conducting an internal seminar or training session will help prevent human error.

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Conclusion
In the 2026 environment, accounting policies are no longer just formal documents gathering dust on a shelf. They are becoming an effective mechanism that allows a company to:

• legally minimize tax risks;

• build an effective internal control system;
• reasonably apply the benefits and preferences provided by law;
• ensure readiness for automated tax control.

Delaying its updating or using outdated regulations creates a situation of uncertainty for businesses, in which every action can be challenged by tax authorities. Investing time and resources in properly developing accounting policies today is an investment in the company's stability and security tomorrow.

One of the most significant changes in 2026 was the halving—from 20,000 to 10,000 MCI—of the threshold at which a company under the general tax regime (GTR) must register as a VAT payer. With the current MCI of 4,325 tenge, the threshold is 43,250,000 tenge.
At first glance, this figure is impressive, and many entrepreneurs might think it won't affect them personally anytime soon. However, experience shows that, amid inflation and rapid business growth, the "day X" arrives sooner than expected. And the cost of delay is higher than ever—the automated system of the State Revenue Committee (SRC) records every tenge of turnover, and any delay in filing an application results in multi-million-dollar fines, additional charges, and account freezes.
To avoid being caught in the crossfire, it's essential to clearly understand the new rules of the game. Let's examine them systematically.

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What exactly is considered taxable turnover for the threshold?
Before tracking your approach to the limit, you need to know exactly what amounts are included. According to Article … of the Tax Code, taxable turnover is defined as the total value of:

• goods of our own production and purchased and sold on the territory of Kazakhstan;
• completed work, rendered services;
• received advances (prepayments) against future deliveries, if such deliveries will be subject to VAT;
• goods transferred free of charge (except in cases expressly exempt from tax).

An important detail: turnover exempt from VAT (e.g., medical services, education, financial services) is not taken into account when calculating the threshold. However, turnover taxed at a zero rate (exports, international transportation) is included in the calculation, as it is considered taxable.
Therefore, if your company combines several types of activities, it is necessary to maintain separate records in order to correctly determine the moment the threshold is reached.

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Three ways to get on the VAT payer register
From 2026, the legislator will provide three options for registration.

1. Voluntary registration. An entrepreneur has the right to submit an application and become a VAT payer even if their turnover has not reached 43.25 million tenge. This can be beneficial if you work primarily with large counterparties who require input VAT deductions, or if you plan to export (the 0% rate entitles you to a tax refund).
2. Mandatory registration. This occurs automatically when taxpayers exceed the 10,000 MCI threshold for the OUR. The obligation arises on the day the threshold is exceeded, and the application deadline begins from that moment.
3. Conditional registration (for foreign companies). New rule from 2026: foreign companies selling goods or services to Kazakhstani consumers through online platforms are included in a special register from the moment they first receive payment from a Kazakhstani buyer. They are recognized as VAT payers without the right to deductions.

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Who was left out of the changes: a complete list of exceptions?
The law clearly defines the circle of persons to whom the mandatory registration requirement does not apply:

• all taxpayers using special tax regimes (simplified declaration, patent, retail tax, fixed deduction, etc.);
• government institutions and state-owned enterprises;
• branches and representative offices of resident legal entities (they are not independent payers);
• private practices: lawyers, notaries, mediators, bailiffs;
• individuals without Sole Proprietor status.

There's a fundamental limitation for those working under the simplified tax system: they cannot be VAT payers. If such a taxpayer was registered before January 1, 2026, they were required to deregister, otherwise they would have to switch to the general tax regime. The choice had to be made by the end of 2025, and the consequences of this choice affected their relationships with their counterparties.

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Application deadlines and procedure
Correctly timing the time after exceeding the threshold is critical. Scenarios for the development of events:

• If the excess occurred during normal business operations (accumulation of turnover day after day), then the five working days are counted from the date following the day of the excess. The application must be submitted within this period.

• If a one-time transaction is planned that clearly exceeds the threshold (for example, a contract for 50 million tenge), the application must be submitted before the transaction is completed—before the goods are shipped or the advance payment is received.

Submission methods:

• electronically - through the “Taxpayer’s Account” or the eGov.kz portal;
• on paper - during a personal visit to the Public Service Center or tax authority.

After receiving the application, the tax authority makes a decision on registration or refusal within 5 business days. The date of registration is considered the date of the positive decision, but the taxpayer is considered registered from the date of application submission (if submitted on time).

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What changes after registration: new responsibilities?
Once a company receives VAT payer status, it automatically falls under additional requirements:

• Issuance of electronic invoices (EIs) with VAT allocated for all taxable transactions. The e-TAMGA system verifies that there are sufficient funds in the account to pay the tax before issuing the EIs.
• Quarterly submission of VAT return (form 300.00) by the 15th day of the second month following the reporting quarter.
• Payment of tax to the budget before the 25th day of the second month after the quarter.
• Maintaining separate records in the presence of turnover taxed at different rates, as well as non-taxable transactions.

Failure to comply with these obligations entails separate fines, in addition to penalties for late registration.

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Consequences of Missing the Registration Deadline: A Financial Cascade
If a taxpayer fails to file a claim on time, they will face not just one, but a series of budgetary penalties.
Administrative fine
Part 3 of Article 269 of the Code of Administrative Offenses of the Republic of Kazakhstan provides for a fine of 50 MCI—216,250 tenge. This is just the beginning.

Fine for unregistered driving
Part 5 of Article 275 of the Code of Administrative Offenses of the Republic of Kazakhstan imposes a penalty of 15% of the turnover generated during the period when the company was required to be registered but was not. For example, if the turnover in the two months following the threshold exceeded was 100 million tenge, the fine is 15 million tenge.

Additional VAT assessment
The tax authority will assess additional VAT at a rate of 16% on the entire amount of taxable transactions made without registration. However, the right to deduct input VAT for this period is lost, as the taxpayer was not entitled to claim it. The final amount of additional assessments may be several times higher than the tax that would have been paid had the company registered on time.

Blocking of bank accounts
If the violator fails to resolve the issue within 30 business days of receiving an official notice from the tax authorities, the State Revenue Committee has the right to suspend debit transactions on the accounts. Without cash flow, the business effectively grinds to a halt.

Penalty for late payment
Penalties are charged on all additional VAT amounts for each day of delay.

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How the Tax Authority Identifies Violators: Digital DetectiveSince 2026, control over compliance with the threshold has been fully automated. The information system of the SRC analyzes in real time the taxable turnover of all taxpayers based on data from:

• bank statements (ASPIR system);
  
• issued EIs (electronic invoices);
  
• customs declarations;
  
• reporting for other taxes.
  

System operation algorithm:

1. When turnover approaches 80% of the threshold (approximately 34.6 million tenge), a preventive notification is sent to the taxpayer in the "Taxpayer Cabinet": "You are close to the threshold, prepare your documents."
   
2. When the threshold is exceeded and there is no application for registration, an official notification is generated requiring the violation to be corrected within a 30-day period.
   
3. If the requirement is not met, a decision is made to block accounts.
   

It is impossible to hide from the automated system: all financial flows are digitized and visible to the tax authority.

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Risks for counterparties: if the seller is not registered on time
Problems arise not only for the violator but also for their customers. If the seller should have registered for VAT but failed to do so, then:

• the invoices issued to him (even if he later registers) do not give the buyer the right to deduct VAT for the period before registration;
• the buyer may lose the right to a deduction if the tax authorities recognize such invoices as invalid;
• The entire supply chain comes under suspicion of an evasion scheme.

Therefore, when selecting suppliers, it is wise to check their VAT payer status through the public services of the State Revenue Committee.

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Practical advice: how to avoid the trap
To avoid becoming one of the violators, implement simple but effective rules in your company:
1. Weekly turnover monitoring. Set up your accounting software to automatically calculate the cumulative total of taxable turnover since the beginning of the year. Monitor your progress toward 40 million tenge.
2. Check your counterparties. Before entering into major contracts, check whether your partner is a VAT payer. This is critical for your deductions.
3. Reserve your registration time. Please remember to allow five business days. Don't leave your application until the last day—allow for possible technical glitches.
4. Planning for major deals. If you're considering a contract worth over 43 million tenge, register in advance. It's better to do this voluntarily than to have to make excuses later.
5. Consult with an expert. If you have any doubts about whether certain transactions are subject to VAT, or if you are combining different tax regimes, consult a tax consultant.

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Frequently Asked Questions
Question: Do I need to register if I work under a simplified regime?
Answer: No, but you can't be a VAT payer. If your business requires VAT, you'll have to switch to the VAT system.

Question: What is considered the date of exceeding the threshold?
Answer: The day when the amount of taxable turnover since the beginning of the year first exceeded 10,000 MCI.

Question: If I register late, can I avoid a fine?
Answer: Only if the tax authorities haven't yet discovered the violation and you filed a report yourself before receiving the notice. In this case, the fine may be reduced or not applied, but additional VAT will still be assessed for the period following the violation.

Question: Are goods received free of charge included in the turnover for the threshold?
Answer: No, gratuitous receipt is not a sale, it is income for corporate income tax, but for VAT it is not taxable turnover.

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Conclusion: New times, new rules
2026 marked the final shift in tax administration to digital. The reduction of the VAT threshold to 43.25 million tenge and automated control mean it's no longer possible to "forget" about registration. The system will detect violations immediately, and the resulting penalties can destroy even a sustainable business.
The only way to keep your company safe is to take your accounting seriously, register on time, and remember that when it comes to dealing with the government, delay is fatal.

The State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan has the ability to compare taxpayer data in real time thanks to the Electronic Invoice Information System (EIIS) and a virtual warehouse.
The concept of "mirror control" has become ingrained in the professional community—an automated comparison of VAT amounts for the same transactions between seller and buyer. While discrepancies could previously go unnoticed for months, today the tax authorities see them almost instantly. Monthly proactive data analysis before filing Form 300.00 has gone from being a recommendation to a vital necessity.

The Anatomy of a VAT Desk Audit in 2026

What is desk audit and how does it work?
A desk audit is a remote analysis of tax reports, electronic invoice data, and cash register information without on- site visits. This is not an audit in the traditional sense, but a tool that allows taxpayers to voluntarily resolve discrepancies.
Since 2026, an important terminology change has occurred: the word " violation " has been replaced with " discrepancy" This is not just a play on words. Now, desk audits are officially positioned as a service tool that gives businesses the chance to correct errors without penalties. However, the essence remains the same: identified irreparable discrepancies lead to a tax audit.

Mirror control mechanism
The system compares two key groups of data:

1. Sale by the seller (lines 300.00.006 “Total turnover” and VAT amount) with the acquisition by the buyer (line 300.00.021 “Total purchased” and VAT amount to be offset).
2. Electronic invoices issued by the supplier and invoices received by the buyer.

If the seller has reflected the sale and charged VAT, but the buyer for the same transaction has not confirmed the purchase (or confirmed it in a smaller amount), the system records a “gap” or “discrepancy.”

Why are "mirrors" so important?
State Revenue Committee has repeatedly emphasized that desk audit notifications are generated based on a comparison of electronic invoice data and tax reporting. For VAT payers, this means that every transaction is closely monitored by an automated system.

Key lines of form 300.00 requiring monthly monitoring
To avoid discrepancies, accountants need to understand which indicators the tax authorities are comparing. According to methodological recommendations, the following lines are compared during a desk audit:

Line Form 300.00	Name	What is being checked
300.00.006	General turnover	Comparison with income in form 100.00 (CIT)
300.00.007	Size turnover	Control of exceeding the threshold for VAT registration
300.00.008	VAT amount	Accrued tax
300.00.014	VAT deductible	The tax that the buyer plans to take as a credit
300.00.021	Total acquired	Expenditures compared with the corporate income tax

But the main “mirror” comparison looks like this: the VAT amount on line 300.00.008 for the seller must match the VAT amount on line 300.00.014 for the buyer for the same transaction.

Common Causes of Discrepancies: What to Look for in Data
Not all discrepancies are errors. Tax legislation allows for objective differences between seller and buyer data. The main goal of the monthly analysis is to separate acceptable discrepancies from those that will raise questions from the State Revenue Committee.

1. Temporary differences
One of the most common reasons is different turnover recognition dates. A seller might issue an invoice in one quarter, while a buyer accepts the goods for accounting and records the purchase in the following quarter. This is why monthly, rather than quarterly, analysis allows us to track such "migrating" amounts and prepare explanations.

2. Adjustments and returns
Reversal invoices, product returns, and price changes after shipment all create temporary "mirror" discrepancies that must nevertheless be synchronized on both sides.

3. Errors in filling out
A basic error is an incorrectly entered buyer's Taxpayer Identification Number (TIN), which prevents the invoice from being processed in their "virtual warehouse." Or technical errors in the amount result in the buyer's VAT being different from the seller's.

4. Differences in accounting for CIT and VAT
It's important to remember: the total annual income (TAI) in Form 100.00 and the sales turnover in Form 300.00 may differ methodologically. Not all income is taxable turnover for VAT, and vice versa. During an office audit, these lines are compared, and the taxpayer must be prepared to explain any discrepancies.

Notification procedure: how it works in practice
If the system detects a discrepancy that has not been resolved prior to filing the report, the taxpayer receives a notification of the desk audit results. The procedure is regulated by Article 96 of the Tax Code and is as follows:

1. Receiving a notification. The document is sent to the taxpayer's online account.
2. Compliance deadline. The law stipulates 30 working days from the day following the day of delivery of the notice.

3. Reaction options:

• Agreement with the discrepancy: additional tax reporting (adjustment) is submitted, the discrepancy is resolved.
• Disagreement with a discrepancy: an explanation of the absence of violations is provided on paper or electronic media with supporting documents attached.

If the taxpayer ignored the notice or failed to justify the discrepancies, the tax authority has the right to order a tax audit.

Monthly Analysis: A Step-by-Step Guide for Accountants
To avoid the risks described, we recommend implementing the following monthly mirror verification procedure.

Step 1. Downloading data from the E-Invoice IS
Generate a monthly discrepancy report in the electronic invoice information system. The system allows you to see invoices that have not been confirmed by the counterparty.

Step 2. Communication with counterparties
Create a discrepancy table and send inquiries to your customers and suppliers. The goal is to find out why the invoice wasn't reflected (technical error, incorrect details, accounting policy) or why your supplier didn't charge VAT on shipments to you.

Step 3. Reconciliation of purchase turnover
Reconcile line 300.00.021 "Total Purchased" with accounting data and information received from suppliers. This is a key step in monitoring incoming VAT.

Step 4. Troubleshooting technical errors
If an error is discovered on an invoice (incorrect amount, tax identification number), a corrected document must be issued. The sooner this is done, the lower the risk that the discrepancy will be reported during the reporting period and trigger a notification.

Step 5. Prepare an explanatory note for acceptable differences. Gather a package of documents substantiating discrepancies that cannot be resolved by adjustments (e.g., different revenue recognition methods). This will form the basis for an explanation to the State Revenue Committee if notified.

Practical recommendations for setting up accounting
1. Work with the trial balance sheet for settlement accounts
Reconciliations with counterparties should be conducted monthly, not quarterly. This is the only way to quickly identify situations where your supplier "forgot" to record sales, but you've already credited the VAT.

2. Monitor your counterparties at the selection stage
Before entering into a transaction, check your counterparty for any problems. Working with a problematic supplier may result in your VAT deductions being deemed invalid.

3. Use automation
Modern accounting software (for example, on the 1C platform) allows for automatic reconciliation of electronic invoice information system data with accounting data. Implementing such tools reduces human error.

4. Maintain a discrepancy register
If objective discrepancies regularly arise in your operations (for example, a long production cycle), maintain a separate register with explanations. This will help you quickly respond to the State Revenue Committee notification.

Responsibility for unresolved discrepancies
Unresolved discrepancies identified during desk audits entail the following consequences:

1. A tax audit is scheduled. This is the least desirable scenario, as the audit could cover a longer period and uncover additional violations.
2. Additional taxes and penalties. If the discrepancy is deemed a violation, the taxpayer will be assessed additional VAT and penalties.
3. Administrative fine. If the offense is confirmed, a fine may be imposed on the official.
4. Inclusion in a risk group. Systematic discrepancies increase the risk management system score, making the company a candidate for more frequent audits in the future.

Conclusion: Preventive Control as a Quality Standard. Monitoring VAT "mirrors" is not simply a requirement of tax authorities, but an element of financial hygiene for modern businesses in Kazakhstan. Since 2026, when the VAT rate increased to 16% and the registration threshold was lowered, the attention paid to VAT payers has increased exponentially.

Monthly analysis of discrepancies before submitting Form 300.00 allows you to:

• Avoid receiving unexpected notifications a month after submitting reports;
• Maintain the right to VAT credit without litigation;
• Avoid a tax audit;
• Build trusting relationships with counterparties and tax authorities.

In the digital age, the rule is simple: the more transparent your "mirrors," the more secure your business.

When doing business with foreign partners, Kazakhstani companies often face questions regarding the taxation of such transactions. One of the most common and complex issues is paying value-added tax (VAT) when purchasing goods and services from a non-resident. Many entrepreneurs mistakenly believe that because the seller is located abroad, there are no tax obligations in Kazakhstan. However, this is not always the case! Who is obliged to pay VAT in principle? Before discussing VAT for non-residents, let's review the general rules for registration. According to Article 447 of the new Tax Code of the Republic of Kazakhstan (hereinafter referred to as the Tax Code of the Republic of Kazakhstan), from 2026, the following are VAT payers: Persons officially registered as VAT payers in Kazakhstan. Persons importing goods into the territory of the Republic of Kazakhstan (importers). When is VAT registration mandatory? The main criterion is income volume. If your annual turnover exceeds 10,000 MCI (monthly calculation indices) in a calendar year, you are required to register for VAT (subparagraph 2, paragraph 4, Article 99 of the Tax Code of the Republic of Kazakhstan). Who need not register? Certain categories of taxpayers are exempt from this obligation (Clause 3, Article 99 of the Tax Code of the Republic of Kazakhstan). These include, for example, government agencies, structural divisions of resident companies, entities operating under special tax regimes, and individuals. However, for our topic, the key rule is this: the obligation to pay VAT for a non-resident arises only for a Kazakhstani buyer who is already registered for VAT. Why does a Kazakhstani company pay taxes for a foreigner? The mechanism by which the buyer pays the tax for the seller is called "reverse VAT charging." In Kazakhstan, this is regulated by Articles 449, 452-460 of the Tax Code of the Republic of Kazakhstan. The essence is simple: according to the law (subparagraph 2 of paragraph 1 of Article 449 of the Tax Code of the Republic of Kazakhstan), if you, as a VAT payer, purchase work or services from a non-resident, and the place of sale of these works/services is recognized as Kazakhstan, then this purchase automatically becomes your own taxable turnover. Since your foreign partner is not registered with the tax authorities of the Republic of Kazakhstan and cannot issue an invoice or pay the tax, this responsibility shifts to you, the Kazakhstani buyer. Important note : It's important to determine whether your non-resident has a permanent establishment or branch in Kazakhstan. If there is a permanent establishment, it can pay the tax, and you will not be liable. An error in this regard can lead to: Fines and penalties; The need to resubmit tax returns; Close attention from tax authorities. When is Kazakhstan considered a place of supply of services? The key question is: when is a service purchased from a foreigner considered sold in Kazakhstan? The answer is provided by Article 459 of the Tax Code of the Republic of Kazakhstan. The territory of the Republic of Kazakhstan is recognized as the place of sale if: Real Estate: Services related to real estate located in Kazakhstan (e.g. design of a building in Almaty). Movable property: Work is carried out with movable property located in Kazakhstan (equipment repair, machine installation at a Kazakhstani plant). Culture and education: Events (concerts, trainings) are physically held in Kazakhstan. Services to the buyer: The most common case is when the buyer of the services operates in Kazakhstan. This includes most of the "business" services listed below. Special case: Even if the contract is signed by the head office of a non-resident company, but the service is actually provided and consumed by a Kazakhstani branch, the place of sale will be Kazakhstan, and the obligation to pay VAT arises for this branch. What services fall under this rule? According to subparagraph 4 of paragraph 2 of Article 459 of the Tax Code of the Republic of Kazakhstan, these include: Transfer of intellectual property rights (patents, trademarks); Rights to use the software, its updating and maintenance; Providing access to Internet resources (websites, cloud services); Consulting services (audit, consulting, marketing, advertising, design); Legal and accounting services; Communication services; Repair, installation, dismantling and assembly work. When do you not need to pay VAT? If the service is included in the list of services exempt from VAT (Article 474 of the Tax Code of the Republic of Kazakhstan) or if the place of its sale is not Kazakhstan, but another country, then there is no need to pay tax. What is the tax base (turnover amount)? The calculation is based on the cost of the purchased work or services, as specified in the contract, invoice, or certificate. Important: this cost also includes CIT (corporate income tax) or PIT (individual income tax) withheld at the source of payment, if you are required to withhold them. If payment is in foreign currency: When paying in dollars, euros, or rubles, the cost must be converted to tenge. For this, the market exchange rate in effect on the last business day preceding the transaction date is used. What's the rate? The standard VAT rate in effect in Kazakhstan, 16%, is applied to the resulting turnover amount. Example: You purchased consulting services from a US company for $1,000. The exchange rate on the last business day before signing the deed was 460 tenge per dollar. Turnover value in tenge: $1,000 * 460 = 460,000 tenge. Amount of VAT payable for a non-resident: 460,000 * 16% = 73,600 tenge. When to pay? The payment deadline is established by Article 506 of the Tax Code of the Republic of Kazakhstan. The tax must be transferred to the budget no later than the 25th day of the second month following the reporting period in which the turnover occurred. The reporting period for most companies under the general tax regime (GTR) is a quarter. Example of calculating the term: You signed the act with a non-resident on July 15. The turnover was completed in July (3rd quarter). The 3rd quarter ends on September 30. The second month after the end of the quarter is November. The payment deadline is November 25th. Is it possible to get back the VAT paid (take it as a credit)? The good news: yes, you can. The VAT amount you paid for a non-resident can be offset (i.e., it reduces your future VAT payments). This is provided for in subparagraph 2 of paragraph 7 of Article 480 of the Tax Code of the Republic of Kazakhstan. Conditions for crediting: You must be a VAT payer. You must have an electronic invoice (EI) issued for this turnover. The VAT amount must be actually paid to the budget, which is confirmed by a payment order. Important limitation: You can only offset a maximum amount of VAT that you've actually paid. You can't offset "virtual" VAT if you haven't yet remitted it to the state. When to read? VAT is credited in the tax period when the electronic invoice was issued (clause 3, article 481 of the Tax Code of the Republic of Kazakhstan). Accounting entries (how to reflect in accounting) To correctly reflect transactions with a non-resident in accounting, use the following posting algorithm: VAT accrual for non-residents: Debit account 1630 (transit account for VAT) — Credit account 3130 (VAT payable).    2. Transfer of VAT to the budget (BCC 105104): Debit account 3130 - Credit account 1030 (money in the current account).   3. Crediting of paid VAT (after payment): Debit of account 1420 (VAT offset) — Credit of account 1630 (transit account). Thus, account 1420 will contain an amount that you can offset against VAT payable in future periods. How to fill out a VAT return (form 300)? In declaration 300.00 these transactions are reflected as follows: The turnover for purchasing services from a non-resident is shown in Appendix 300.05 and entered in line 300.00.14. The VAT amount you calculated for a non-resident this quarter is indicated in line 300.05.002. This is the amount that must be paid by the 25th of the second month of the following month. The VAT amount you've already paid and are eligible to claim as a credit is reflected in line 300.05.007. This same amount is transferred to the final line 300.00.014. Important : Make sure that the register of purchased goods, works, and services (Appendix 300.08) does not accidentally include invoices for services provided by non-residents outside of Kazakhstan. Special case: if the buyer is not a VAT payer If a Kazakhstani company or Sole Proprietor is not registered for VAT (for example, it operates under a simplified tax system or its turnover is less than 10,000 MCI), then when purchasing services from a non-resident, there is no obligation to calculate and pay VAT for the non-resident. This follows directly from Article 449 of the Tax Code of the Republic of Kazakhstan: only VAT payers must include purchases from non-residents in their own taxable turnover. However, this turnover is taken into account for the purposes of calculating the threshold. Therefore, companies that are not subject to VAT but purchase services from non-residents must be diligent in monitoring the 10,000 MCI threshold. Summary: The buyer's status (VAT payer or not) is the main factor determining your obligations when working with foreign partners. Be careful, correctly determine the location of service delivery, and be mindful of payment deadlines to ensure your business remains financially secure.

The 2026 Tax Code imposes strict requirements on companies that combine different activities. If your business operates in segments with different tax statuses, separate VAT accounting becomes a mandatory requirement rather than a recommendation. Let's look at how to organize this process without errors and with maximum benefit. When the separate accounting mode is enabled The legislation activates the requirement for separate accounting in the presence of at least two categories of transactions from the following list: Standard taxable turnover - sale of goods, works, services at a rate of 16% (base rate for 2026); Zero rate - export deliveries, international transportation and other operations provided for in Article 394 of the Tax Code of the Republic of Kazakhstan; Tax-exempt transactions are the types of activities listed in Article 395 of the Tax Code of the Republic of Kazakhstan (for example, financial services, certain medical services, educational services, etc.); Reduced rate transactions - this applies to the pharmaceutical and medical sectors from 2026 (5%, transitioning to 10% in 2027). An important clarification: even if a company has only one operation that is not subject to general taxation, the separate accounting system must be fully implemented. Two calculation methods: which one to choose? Article 407 of the Tax Code offers taxpayers a choice between two approaches. Each has its own advantages and limitations. Proportional distribution method The essence of the method: the amount of VAT accepted for offset is determined by calculation - as a share of taxable turnover in the total volume of sales. When to apply: if it is impossible to accurately track the purposes for which specific purchases were spent; with a large number of heterogeneous costs; if the share of non-taxable transactions is insignificant. Feature: The proportion is calculated quarterly (or monthly) based on the current period's data. No year-end adjustments are made unless otherwise specified by the accounting policy. Direct separate accounting method This approach requires organizing accounting so that each input VAT amount is clearly linked to a specific activity. To achieve this, all acquisitions are divided into three groups: Benefit-generating costs are goods, works, and services intended exclusively for VAT-taxable transactions. The tax on these costs is fully deductible. Non-taxable costs are resources used only in activities that are exempt from tax or taxable under other rules. Input VAT on these costs is not deductible and is treated as expenses. Mixed expenses are purchases that cannot be clearly classified into the first or second group. VAT for these expenses is allocated according to the rules established in subparagraph 3 of paragraph 2 of Article 409 of the Tax Code of the Republic of Kazakhstan. Important: The selected method is recorded in the accounting policy and does not change during the calendar year. Algorithm for working with mixed costs The following procedure is used to distribute VAT among expenses that have a dual purpose: The total VAT amount is collected for all mixed purchases for the period. The share of taxable turnover (including the zero rate) in the total volume of sales is calculated. The resulting coefficient is multiplied by the total VAT amount for mixed costs – this is the portion of the tax that can be credited. The remaining amount is written off as expenses that do not reduce the tax base. Calculation example: The total amount of VAT on mixed costs is 1,000,000 tenge. The share of taxable turnover is 70%. The following is accepted for credit: 1,000,000 × 0.7 = 700,000 tenge. Not accepted: 300,000 tenge. How to reflect separate accounting in the declaration Form 300.00 does not provide detailed disclosure of the separate accounting method. However, the fact of its use is recorded by making a corresponding mark in the declaration. When filling out the report, it is necessary to reflect: on line 300.00.025 II B - the amount of VAT permitted for offset during separate accounting; on line 300.00.026 II - the amount of tax not accepted for offset. These indicators are formed on the basis of analytical accounting data and calculations performed in accordance with the selected method. What changed in 2026 The increase in the base rate to 16% increases the importance of proper distribution. A 10% error on turnovers of hundreds of millions of tenge can result in millions in losses or additional charges. The new registration threshold is 10,000 MCI (approximately 43 million tenge). Companies approaching this level must assess their turnover structure in advance and prepare their accounting systems for the possible transition to VAT. A ban on combining the simplified tax system and VAT. If a company under a special tax regime has mixed turnover and wishes to remain a VAT payer, it must switch to the general tax regime effective January 1, 2026 (notification must be submitted by March 1). Export transactions remain taxed at a 0% rate, but are included in the total taxable turnover. This is important both for calculating the proportion and for monitoring the registration threshold. Tightening controls. If violations are detected, taxpayers are notified with a 30-day deadline to correct the violation. Instead of deregistration, temporary blocking of electronic invoice statements is now the practice. Typical mistakes and their consequences Error 1: Lack of separate accounting in the presence of non-taxable transactions. Consequence: the tax authority may declare the entire claimed offset invalid and assess additional tax and penalties. Error 2: Incorrect allocation of mixed costs. Consequence: either underestimation of tax payable (risk of additional charges) or unjustified allocation of amounts to expenses (loss of working capital). Error 3: Changing the accounting method during the year without justification. Consequence: the results of such accounting may be declared invalid. Error 4: Ignoring transactions with reduced rates. Consequence: incorrect calculation of proportions and, as a result, errors in the score. Practical recommendations for setting up accounting. Document your methodology. Your accounting policy should include: description of the selected method of separate accounting; the procedure for calculating the proportion (frequency, formula); list of costs classified as mixed; documentation rules. Set up analytics in your accounting system. Your accounting software should allow you to: group costs according to their relationship to types of activities; automate distribution calculation; generate registers for verification. Ensure that preferential rates are applied correctly. Maintain separate records for transactions taxed at the 5% rate from day one. Don't mix them with transactions taxed at the general rate. Conduct regular audits of your calculations. Check quarterly: compliance of the actual distribution with the approved methodology; the correctness of determining the share of taxable turnover; justification for classifying costs as mixed. Plan for tax implications. When changing your business structure (creating new activities, increasing exports), assess in advance how this will affect VAT distribution. Final conclusions Separate VAT accounting in 2026 is not just a code requirement, but a tax burden management tool. When properly organized, it allows for: legally minimize input VAT losses; avoid claims during inspections; build a transparent accounting system that is understandable to both taxpayers and auditors. The key to success is a clear methodology, well-established analytics, and regular monitoring. Without these, even minor errors can lead to significant financial losses.

VAT recovery is the mirror process of tax offsetting (crediting). If you credited VAT (reducing your budget liability) when purchasing inventory items or fixed assets, but these assets are subsequently used in transactions not subject to VAT or are disposed of for reasons unrelated to sale, you are obligated to "return" the previously credited tax to the budget. This mechanism is enshrined in the Tax Code of the Republic of Kazakhstan and aims to maintain tax neutrality: VAT should ultimately be either credited or applied to expenses, but not both.

The essence of the procedure: tax refund to the budget
VAT recovery means that the tax amount previously validly credited is excluded from the VAT credit and is payable to the budget. Essentially, you reverse the previously made credit entry. This is necessary because the continued use of the asset no longer generates taxable turnover, and therefore the right to credit is lost.
Main cases of VAT recovery
Based on the provisions of the Tax Code, we distinguish two main situations:

1. Write-off of inventory. This is the most common occurrence following an inventory count.
   

• Reason: Inventory is removed from circulation not as a result of sale (which is subject to VAT or exempt from it), but as a result of damage, theft, shortage, expiration of shelf life, obsolescence or force majeure.
• Action : If VAT was offset when purchasing these inventory items, this tax must be restored when they are written off. Exceptions include write-offs within the limits of natural loss standards, as well as write-offs due to emergency situations (documented), where the procedure may be different.

    2. Transfer of inventory or fixed assets for non-taxable transactions.

• Reason: Assets originally acquired for use in taxable activities (e.g., for the production of products whose sale is subject to VAT at a rate of 16% or 0%) are now used in tax-exempt transactions. Non-taxable transactions include, for example:

- sale of goods/services exempt from VAT (medical services, some financial services, etc.);
- transfer of property as a contribution to the authorized capital;
- the use of goods for one's own non-production needs (for example, for free distribution, representative purposes), if such transactions are not recognized as taxable turnover.

• Action : On the date of such transfer (or commencement of use in non-taxable transactions), previously credited VAT is subject to recovery.

Reflection in accounting
In accounting, VAT recovery is usually processed by reverse posting or by assigning the tax amount to the appropriate cost or other expense accounts.

Situation	Entry	Explanation
Write-off of inventories (shortage, damage)	Debit account 7470 "Other losses" — Credit account 1420 "Value added tax to be reimbursed" (or 3130 "VAT")	The VAT amount is charged to the company's losses
Write-off of inventories within natural loss norms	Debit account 7010 "Cost of goods sold and services rendered" (or 7210, 8310) — Credit account 1420/3130	The reversed VAT increases the cost of goods sold or period expenses
Transfer of inventories/fixed assets for non-taxable transactions	Debit account 7210 "Administrative expenses", 7410 "Expenses on disposal of assets", etc. — Credit account 1420/3130	The debit account depends on the direction of use (administrative needs, disposal, etc.).

Reflection in tax reporting (form 300.00)
The VAT recovery procedure is recorded in the value added tax return (form 300.00).

1. Reflection of the amount: The amount of recovered VAT is indicated in the line designated for adjusting the amount of VAT credited. This effectively reduces the total amount of VAT you can credit for at the end of the period.
2. Restoration periods: Restoration is made in the tax period in which the event occurred (write-off, transfer to non-taxable transactions).

Key point for 2026: responsibility for counterparties
In the context of VAT reinstatement and tax management in general, it's crucial to consider the new realities of 2026. With the entry into force of the new Tax Code (Article 166 ), the right to a VAT credit or refund now directly depends on the integrity of the entire supply chain. If your supplier or their counterparties encounter any problems (such as arrears, failure to respond to a counter-audit, criminal proceedings, or electronic invoice blocking), this may become grounds for denial of a VAT refund or for the credit to be deemed invalid.

What does this mean in the context of recovery:
If you fail to recover VAT when writing off inventory items purchased from a problematic supplier, a tax audit may:

1. Admit that you have unreasonably failed to restore the VAT.
2. Assess additional taxes, penalties and fines.
3. Refuse to refund other VAT (for example, export VAT), citing the presence of risks in the entire supply chain.

Resume
VAT recovery is a mandatory procedure when disposing of inventory or changing its intended use. Its purpose is to eliminate double benefits and align tax accounting with the actual use of the assets.
l  When writing off inventory: Recover VAT if it was credited and record it as an expense/loss. Exceptions include documented natural loss rates.

• When transferring to non-taxable transactions: Recover VAT on the date of transfer.
• Documentation: Always have write-off certificates, managerial orders, and explanatory notes from the Ministry of Labor. This will protect you during a tax audit.
• Tax reporting: Reflect the recovered amounts in the VAT return (form 300.00) for the period in which the event occurred.
• 2026 context: Keep in mind that tax authorities are now assessing risks across the entire supply chain. Accurate and timely VAT recovery is an important element of your tax security.

If you have any questions about a specific situation (for example, a write-off due to force majeure or the transfer of fixed assets for VAT-exempt leasing), it's best to consult a professional tax advisor. I'm ready to help you understand the details!

EI (electronic invoice) is a digital analog of a regular paper invoice used for VAT accounting. In Kazakhstan, this is an official tax document that confirms the fact of a transaction and the amount of tax that the seller has charged to the buyer.

• Legal force. An EI has the same legal force as a paper document. The original is considered to be the electronic file stored in the state information system, not its paper copy.
• Mandatory details. The document is completed in an approved form and contains all the same data as the paper version: names of the parties, their details, list of goods or services, cost, and VAT amount.
• Electronic signature. An EI must be certified with an EDS (electronic digital signature) of the authorized person of the supplier. Without a signature, the document is invalid.
• Registration in the system. The document is issued through a special portal — the Electronic Invoice Information System (EI IS). After verification, the system assigns a unique registration number, and only then the document is considered executed.
  

Who Is Required to Issue EI
By law, the following must issue electronic invoices:

• VAT payers;
• companies that sell imported goods;
• participants in transactions exceeding 1,000 MCI (monthly calculation index);
• certain other categories of taxpayers.
  

Types of EI
In addition to the standard invoice, the system allows the issuance of:

• corrected — when it is necessary to change or supplement data in a previously issued document;
• additional — when it is necessary to adjust the turnover amount.
  

Why Is This Needed
The main function of an EI is to give the buyer the basis to claim VAT as a credit. For businesses, it is also convenient: documents are delivered instantly regardless of distance, there is less risk of errors due to automatic system verification, and there is no need to store mountains of paper.

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Deadlines That Cannot Be Missed

Fifteen days for everything.
By default, the law gives you exactly fifteen calendar days from the date of the transaction to issue an invoice. Not a day more. This applies to ninety percent of operations that an ordinary company performs.

Some think that you can wait until the last minute and still make it. In practice, those who delay eventually miss deadlines, because there is always something urgent — an employee gets sick, a server goes down, the director leaves town. The only working method is to set an internal company limit of five business days for issuing an EI. Then you have a buffer of almost a week and a half for force majeure.

For certain categories of businesses, it is permitted to issue invoices once a month, based on period results. Then the deadline is the twentieth day of the following month. But this is not for everyone. Before relaxing, make sure your company actually falls under the exception.

Five days for non-residents
A separate issue is transactions with foreigners. If a non-resident has provided you with a service or performed work, the place of supply of which is recognized as Kazakhstan, you are required to issue an EI addressed to yourself. This must be done within five calendar days after paying the VAT to the budget.

Important nuance: first the payment, then the document. Not the other way around. If you issued an invoice before paying the tax, you have violated the procedure. Formally, the document appeared before the basis for its existence arose.

Payment can be made either with actual money or by offsetting an overpayment. In the latter case, the five-day period begins to run from the moment when the tax authority carried out the offset. Not from the day you submitted the application, but precisely when the officials pressed the button.

Fifteen days to chase the supplier
Previously, a buyer had six months to demand an invoice from the supplier. Now — only fifteen calendar days after the transaction date. Miss it — consider that you have lost the right to demand.

A supplier who receives a demand within this period is required to issue the document no later than thirty days after the transaction date. If the supplier delays — that is your problem. In contracts, it is now mandatory to stipulate that the party delaying the issuance of an EI compensates the other party for all tax losses. Otherwise, you will be left without the credit and without the money.

Ten business days to respond to the tax authority
If a notification regarding comparative control arrives, you have ten business days. Not calendar days, but business days. Either you prove that everything is legitimate, or you revoke the suspicious invoices. There is no third option.

Those who ignore notifications quickly find themselves unable to issue EIs and without access to bank accounts. Moreover, the blocking occurs automatically, without additional warnings.

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Confirmation from the Buyer — Now Mandatory

If the buyer is a VAT payer
As of this year, corrected, additional, and revoked invoices are considered executed only after the buyer has confirmed them. The system no longer accepts unilateral actions by the supplier.

The buyer has ten calendar days to either click "confirm" or "reject." If the buyer remains silent for all ten days — a legal uncertainty arises. The tax authority during an audit may consider that the document was not agreed upon and disallow the credit.

Therefore, contracts must now state: the buyer undertakes to check incoming EIs daily and respond within three business days. Otherwise, losses are borne by the buyer.

If the buyer is not a VAT payer
For such entities, the mechanism is simpler. If they do not reject the document within ten days, it is automatically considered confirmed. Nothing needs to be done.

But in practice, it is better not to rely on autopilot. Inexpensively training the counterparty on how to log into the system and check documents pays off by avoiding future problems.

What to Do Inside the Company
To avoid missing incoming confirmations, three things must be done:

• assign a specific person who checks the incoming EI section daily;
  
• specify in the regulations that the response to an incoming document must be within three business days;
  
• set up notifications by email or messenger for each new arrival.
  

It sounds mundane, but it is precisely in these small details that people most often fail.

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Biometry — Three Times and You Are Free

When it is required
Biometric identification is required in two cases: during initial registration in the system, and when signing an EI if the taxpayer has fallen into the risk group.

How many times to go through
A total of three successful passes. After the third, the system gives the green light, and invoices can be issued without biometry.

The limit of three times is a gift. But if you have exhausted three passes and continue to undergo biometry every day, it means either you are unaware of the rules or you have configuration issues.
Statuses You Need to KnowNew document statuses have appeared in the system:

• "waiting for biometry" — the document is pending until the responsible person confirms their identity;
  
• "biometry not completed on time" — you were late, the document did not go through;
  
• "deleted due to lack of biometry" — the system simply discarded the document, it no longer exists.
  

If you see the last status, create the document anew. There is nothing left to correct.

What to Do to Avoid Trouble

• check which employees have a valid EDS (electronic digital signature);
  
• explain to everyone how biometry works and why it is needed;
  
• keep track of how many times each employee has already undergone the procedure;
  
• when there is only one pass left before the limit, plan the issuance of large documents so as not to end up in a deadlock.

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Non-Residents — An Eternal Headache

How to issue a document for a foreigner
You purchase a service from a foreigner, the place of supply is Kazakhstan. You are required to issue an EI to yourself. In the supplier field, you enter the details of the non-resident; in the recipient field, you enter your own details.
You must check the box in the system indicating that the document is being issued in connection with an acquisition from a non-resident. Without this mark, the tax authority may assume that you simply made a mistake and refuse the credit.

The main rule
First pay the VAT, then issue the EI. Five days for everything from the moment of payment.
Payment is either a transfer of money or an offset of overpayment. In the latter case, the date of payment is considered to be the day when the tax authority carried out the offset. Not the day you submitted the application, but the day when they got around to it.
What penalties apply for errors

• did not pay the tax — a fine;
  
• paid late — a fine;
  
• issued the EI before payment — violation of procedure, the credit may not be recognized;
  
• incorrectly filled in the details — redo it, lose time, get stressed.

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Control — They Are Watching You

E-Tamga
This is a new service that calculates your balance. If you are in the risk group, you can issue EIs only within the limits of confirmed expenses.
The balance is replenished by depositing money into the treasury account of the SRC (State Revenue Committee). No advance tax is charged on this — which is a plus. Not only suppliers themselves can replenish the balance, but also their buyers.
The control lasts twelve months. If you want to exit earlier, you can submit an application after six months under two conditions: you have regularly replenished the balance every month and have spent at least half of the VAT amount indicated in your EIs.

Comparative Control
This is where they look for those who trade in thin air. If the tax authority finds suspicious transactions in your records, a notification will arrive. Ten business days — either provide explanations or revoke the documents.

If you fail to meet the deadline — EI issuance is blocked, accounts are frozen. Getting out of this situation is long and expensive, so it is better not to let it come to that.

Fines
The first violation in a year — a warning. The second — a fine. The amount depends on who you are: large business, medium, or small.

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How to Build a System to Avoid Missing Deadlines

Internal Regulations
Take it and write it down on paper:

• employees responsible for business operations transfer primary documents to the accounting department within a maximum of three business days;
  
• the accounting department issues an EI within a maximum of five business days from the moment of receiving the documents;
  
• the person responsible for incoming EIs checks them every day and confirms them within three days;
  
• if a notification from the tax authority arrives, they report it to the director on the same day.
  

Without a written document, you are nobody. When regulations exist, you can hold people accountable. When there are no regulations, everyone will do as they please, and in the end, the director will be the one to answer.

Automation
Set up integration of 1C with the EI IS (Electronic Invoice Information System). This is not difficult or expensive, and it provides:

• automatic generation of invoices;
  
• real-time status tracking;
  
• deadline approaching notifications;
  
• batch issuance for similar types of transactions.
  

Manual work kills time and multiplies errors. Automation pays for itself within a couple of months.

Calendar
Hang on the wall or keep in your phone a list of dates:

• the 5th, 10th, and 15th of each month — check VAT for non-residents;
  
• the 15th — reconciliation of all transactions from the previous month;
  
• every Friday — review of incoming EIs for the week.
  

When the dates are in front of your eyes, there is less chance of missing something.

Technical Failures
If the system goes down, and this is confirmed by the SRC (State Revenue Committee), you can issue paper invoices. Later, when the system is back up, you will have fifteen days to register them electronically. Fines do not apply in this case.
The main thing is not to forget to register them afterwards. Otherwise, the paper will remain paper, and the tax authority will not see it.

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Mistakes That Everyone Makes

No confirmation from the buyer

• You issued a corrected EI and relaxed. But the buyer did not confirm it because they forgot, did not notice, or their employee left. After a month, the tax authority says — the document does not exist.
• Solution: before issuing the correction, call the buyer and arrange for them to confirm it. In the contract, stipulate the obligation to confirm within three days.
  

Silence in response to notifications

• A letter arrived from the tax authority, you put it in the drawer, thinking — we will deal with it later. After ten days, accounts are blocked.
• Solution: appoint a person who checks notifications every day. If something arrives, they immediately report to the director. Otherwise, you may not be in time later.
  

Errors in non-resident details

• For companies from the EAEU (Eurasian Economic Union), a BIN (Business Identification Number) is mandatory. For companies from far abroad — it is not. Get it mixed up — you receive a registration refusal.
• Solution: create a reference sheet with examples of how to fill out the details for each country. Hang it over the employee's desk.
  

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Briefly About the Main ThingTo avoid paying fines and wasting nerves in 2026, you need to do five things:

• meet the deadlines: fifteen days for regular transactions, five days for non-residents;
  
• make buyers confirm corrected EIs;
  
• monitor biometry and do not exceed the three passes;
  
• check notifications from the tax authority every day;
  
• automate everything that can be automated.
  

Everything else is a consequence. If these five points are working, you will have no problems with EIs. If at least one point is lacking — expect trouble.

Who is required to act according to the new rules?
Article 454 of the Tax Code, as amended in 2026, establishes an additional function for Kazakhstani VAT payers when working with foreign partners.
Mandatory conditions for the application of the norm:

• The operation is of a paid nature (there is a fee)
• Place of implementation – territory of the Republic of Kazakhstan
• The service/work is subject to VAT
  

Categories of payers:

Group	EI liability for a non-resident	Comment
VAT payers (general regime)	Arises when conditions are met	Main category
VAT payers (STR)	Does not arise	Only upon import of goods
Non-payers of VAT	Does not arise	Regardless of status
Individuals	Does not arise	Personal consumption

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Full list of exceptions 
 The legislation provides for a wide range of situations when issuing an electronic invoice for a non-resident is not required.

Exceptions By status recipient

• Organizations without VAT – companies and Sole Proprietors not registered for VAT
• Individuals – acquisition of services for needs not related to entrepreneurship

Exceptions By character operations

• Exempt turnover – services from the list of Article 474 of the Tax Code of the Republic of Kazakhstan
• Foreign place of sale – the service is considered to be provided outside of Kazakhstan
• Gratuitousness – absence oncoming provision

Technical and special exceptions

• Customs integration – services are included in the import price, VAT is paid upon import
• Astana Hub – the recipient has the appropriate status
• Internal turnover of a non-resident – services rendered by a Kazakhstani division of a foreign company (Article 452 of the Tax Code of the Republic of Kazakhstan)
• Electronic commerce – services in electronic form under Section 21 of the Tax Code of the Republic of Kazakhstan
  

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Mechanics of the Process: Inversion of Document Flow
The fundamental difference of the new procedure is the reversal of roles in the traditional "supplier-buyer" scheme.

Traditional scheme: Supplier (seller) → issues an EI → Buyer (recipient)

New reality: Service recipient → creates an EI on behalf of the non-resident supplier → signs it with their own EDS

Filling algorithm:

EI Field	What to Indicate
"Supplier" section	Details of the foreign counterparty
"Recipient" section	Your own details
Signature	EDS of the service recipient

Important nuance: the sequence of actions is strictly regulated – first payment of VAT, then execution of the document.

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Time parameters: link to payment
Unlike the standard procedure, where the period is calculated from the date of the transaction, a special rule applies to electronic invoices issued for a non-resident.
Registration period: starting from the date of VAT payment to the budget and no later than 5 (five) calendar days following the day of such payment.

Responsibility of the recipient: When executing a document, the recipient independently determines:

• turnover amount (tax base);
• date of the transaction;
• the moment of acceptance of VAT for offset.
  

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Determining the date of the turnover
Getting this date right is critical to the entire subsequent chain.
Basic rule: The date of turnover is recognized as the earlier of two dates:

• Payment date – the day of transfer of funds to a non-resident (in full or in part)
• The date of signing the act is the day of documentary confirmation of the fact of provision of services
  
  

Examples: Situation A: The act was signed on March 10, payment was made on March 25.
Turnover date = March 10 (early date)

Situation B: The advance payment was transferred on April 5, the act was signed on April 20.
Turnover date = April 5 (early date)

Special case – related parties : If a non-resident is an affiliated party (head office, parent company), the date of turnover is recognized as the day the transaction is reflected in the accounting records of the recipient.

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Methodology for calculating the tax base
The size of taxable turnover is determined according to the following algorithm.
Step 1. Defining the base
The contractual cost of works/services, recorded in the primary documents, is taken as a basis:

• contract (agreement);
• invoice (bill);
• certificate of completion of work;
• other documents confirming the cost.
  

Step 2. Currency conversion
If the price is expressed in foreign currency:

• The official exchange rate of the National Bank of the Republic of Kazakhstan is applied.
• The rate is taken on the date of the turnover (defined in Part 5)
• The resulting amount is rounded to the nearest tenge according to the established rules.
  

Step 3: Including Additional Costs
Taxable turnover includes all expenses associated with receiving the service, unless otherwise provided by the contract (transportation costs, insurance, agency commissions, etc.).

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Conditions for including VAT in the offset
The right to deduct tax arises when three mandatory conditions are met (clause 2 of Article 454 of the Tax Code of the Republic of Kazakhstan).

Condition 1. Actual payment to the budget
✓VAT calculated for a non-resident must be actually transferred to the budget
✓ Confirmation – a payment order with a bank stamp confirming execution
✓ The payment date is fixed and affects the timing of electronic invoice processing

Condition 2. Registration of electronic invoices in the system
The document must go through the full cycle:

• created in the EI IS (Electronic Invoice Information System);
• signed with the EDS (Electronic Digital Signature) of the recipient;
• registered (a registration number has been obtained).
  

Condition 3: Compliance with the Execution Deadline
The EI must be issued no later than 5 calendar days after payment of the tax.

Moment of credit: Upon fulfillment of all conditions, VAT is claimed as a credit no earlier than the date of the transaction.

Condition	Compliance Criterion	Consequences of Non-Compliance
Payment to the budget	Existence of a payment document	Credit impossible
Registration of EI	Existence of a registration number	Credit impossible
Execution deadline	≤ 5 days after payment	Shift of the credit date

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A practical checklist for deadlines
For convenience, we will present all critical dates in a single table.
Table of key dates

Parameter	Value	How to Determine
Transaction date (TD)	The earlier of the payment date or the certificate date	Compare the documents
VAT payment deadline	By the 25th day of the month following the month of the TD	Calendar
Start of EI issuance period	The day of VAT payment	Date of the payment order
End of EI issuance period	5 calendar days after payment	Payment date + 5 days
VAT credit date	TD (if the issuance deadline is met)	См. графу 1

Example Calculation:
Initial data:

• Certificate signed: March 5
• Payment to non-resident: March 15
• VAT paid to the budget: March 20
  

Calculation:

1. Transaction date = March 5 (earlier date)
2. VAT payment deadline is met (by April 25)
3. EI issuance period: March 20-25 (5 days)
4. If issued on March 22: VAT credit date = March 5
   

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Summary: Step-by-step action plan
To ensure compliance and maintain your right to offset, follow this simple sequence:
Step 1. When receiving documents from a non-resident, determine the turnover date (the earlier of the payment or act date)
Step 2. Calculate VAT at the exchange rate on that date
Step 3. Pay the tax to the budget (before the 25th of the following month)
Step 4. Within 5 calendar days of payment, generate an electronic invoice in the Electronic Invoice Information System, specifying:

• in the supplier – non-resident data;
• in the recipient - your details
  

Step 5. Sign the document with your digital signature and verify that you have received the registration number.
Step 6. Record the VAT offset date (turnover date) in accounting

The system of goods traceability through accompanying waybills (GAW) has become for Kazakhstani businesses a tool that either ensures accounting transparency or creates serious problems. An error in the document today is equated to a tax offense with corresponding sanctions. Let us examine in detail the mechanism of operation, deadlines, fines, and practical tips.

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Evolution of GAW: What Has Changed Since 2023
Until recently, the list of goods subject to mandatory GAW issuance was significantly broader. However, Order of the Minister of Finance of the Republic of Kazakhstan No. 278 dated March 15, 2023 introduced radical changes.

Current List of Mandatory Cases
Today, GAW must be issued only in a limited number of situations.

• Excisable products — this is the first and most controlled category. This includes alcohol and tobacco products, petroleum products, and biofuel. For this group, the strictest requirement applies: mandatory linkage to the Virtual Warehouse in the EI IS. Any movement of such products without being reflected in the virtual space is equated to a violation.
• Equipment from the list of 11 HS codes — a separate category that includes refrigerators, freezers, and certain types of household appliances. These goods fall under international traceability agreements, so their movement also requires mandatory GAW issuance with linkage to the Virtual Warehouse.
• Cross-border operations within the EAEU — import and export of goods between member states of the union. In this case, GAW is mandatory, but without linkage to the Virtual Warehouse. The logic here is different: control is exercised at the border, not through virtual balances.
• Grain crops — a specific category requiring GAW issuance upon export and import to EAEU countries. For grain, a special accounting regime applies, taking into account the specifics of this market and the requirements of agricultural legislation.
• Important nuance: for the remaining categories of goods (more than 3,500 codes), the obligation to issue GAW has been abolished. Companies may use them voluntarily, but this is not a mandatory requirement and remains at the discretion of the business.
  
• Retail Segment: Exception to the Rule. If you sell goods to end consumers through a retail network, issuing GAW is not required. This is directly established by regulatory documents and has been repeatedly confirmed by explanations from authorized bodies. Retail sales are excluded from the traceability system precisely because the end consumer does not participate in the further circulation of the goods and does not create risks for tax control.
  

Timeframe: When the Document Must Appear in the System
Article 176 of the Tax Code establishes a strict requirement: the registration moment of the GAW must precede the start of the physical movement of goods.

Practical interpretation:

• If goods are shipped from a warehouse at 10:00 AM, the GAW must be registered in the EI IS before 10:00 AM.
• If goods are handed over to a carrier on Friday evening, the document must be in the system before the moment of handover.
• If you issue a document retroactively — that is already a violation.
  

Exceptions to Be Aware Of
For import-export operations within the EAEU, GAW may be issued based on data obtained from navigation seals if the goods are transported by road.

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Mechanism of Tax Risks: How One Error Hides an Entire Turnover

Let us consider a typical situation that leads to serious consequences.
Scenario: "Erroneous GAW"

1. A company ships goods, but an error is made in the GAW (incorrect quantity, incorrect BIN of the recipient, wrong product code).
2. The recipient rejects the document, or the system automatically records a discrepancy.
3. The goods have physically left the warehouse, but in the virtual space of the EI IS, they continue to be "listed" as belonging to the sender.
4. The tax authority conducts a reconciliation: the balances in the virtual warehouse do not match the actual movement.
5. An automatic notification of discrepancy is generated.
   

Interpretation of the Tax Authority
From the perspective of fiscal authorities, if goods are not written off from the virtual warehouse through a correct GAW, then no sale has taken place. Accordingly, the sales turnover is not reflected, and taxes have not been calculated.
Chain of Consequences

• Additional assessment of CIT and VAT
• Penalties for each day of delay
• Fine under Article 283-1 of the Code of Administrative Offenses of the Republic of Kazakhstan
• Possible blocking of accounts if explanations are not provided
  

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Navigating Corrections: Deadlines and Algorithms
If an error is detected, action must be taken according to the strict procedure established by the GAW Issuance Rules.
Permissible Correction Periods

Conditions supplies	Period For review / correction	Comment
Delivery by road, rail, and air	20 working days from the date of registration	Including weekend after recount
Broadcast without use transport	10 calendar days from the date of registration	For example, when transferring to a warehouse

Ban on recall
A GAW (Goods Accompanying Waybill) issued upon import/export of goods within the EAEU, if there is confirmation of border crossing, is not subject to revocation.

Step-by-Step Instructions When an Error Is Detected
Step 1: Initiate revocation

• If the recipient has not yet confirmed the document, revocation is carried out unilaterally.
• If the document has been confirmed, coordination with the recipient is required.
  

Step 2: Create a new GAW

• The new document must contain the correct data.
• The shipment date (transaction date) must be the actual date.
• The issuance date of the new GAW will be the current date.
  

Step 3: Assess the consequences

• A violation of the requirement to issue the GAW before the start of shipment occurs.
• This is grounds for administrative liability.
  

Special Case: Rejection of GAW by the Recipient
If the counterparty rejects the document after the established deadlines, and an EI has already been issued based on it, a special rule applies (clause 30-3 of the Rules):

• The supplier is required to issue a new GAW.
• Issue an EI based on it.
• Deadline for execution: 3 working days from the date of rejection.
• The new GAW must include the number of the rejected document.
  

This mechanism allows avoiding violation of EI issuance deadlines, which are normally 15 calendar days from the date of the transaction.

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Penalties: Risk Table
Administrative liability for violations in the sphere of GAW is provided for by Article 283-1 of the Code of Administrative Offenses of the Republic of Kazakhstan. The amounts of fines depend on the business category and the severity of the offense.

Fine Table (in MCI)

Nature of Violation	Individuals	Small Business	Medium Business	Large Business
Absence of GAW or violation of deadlines	5	10	20	30
Repeated violation within a year	10	20	40	60
Repeated violation within a year	10	20	40	50
Repeated incorrect indication of data	20	40	80	100
Turnover of excisable goods without GAW	20	50	100	200 + confiscation

Critical Warning
For the turnover of excisable goods (alcohol, tobacco, petroleum products) without issuing a GAW, not only confiscation of the goods themselves is provided, but also the seizure of income received from their sale.

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Virtual Warehouse: Features of Functioning

The "Virtual Warehouse" module in the EI IS is an integral part of the GAW system. Understanding how it works is critically important.

Unallocated Warehouse: What It Is
If the recipient of goods does not have a registered virtual warehouse (for example, they are engaged in retail trade or are not registered in the EI IS), the goods are automatically transferred to an unallocated warehouse.
This is not an error! The system creates such a warehouse automatically for all users and for recipients engaged in retail sales.

Typical Misconceptions and Risks

1. Misconception: "If the counterparty does not have a warehouse ID, a GAW cannot be issued"
   Reality: The presence of a warehouse ID is not a mandatory condition. The goods will be delivered to the recipient's unallocated warehouse.
   
2. Misconception: "You can reject a GAW because our warehouse is not specified"
   Reality: Such rejection may be deemed unjustified and create problems for both parties.
   
3. Risk: In the event of an unjustified rejection of a GAW and subsequent cancellation of the EI, the supplier falls into strict timeframes for issuing new documents.
   

Regular monitoring: minimum frequency. For control purposes, it is recommended to reconcile virtual warehouse data:

• For excisable goods - daily
• For other products - weekly
• Complete inventory of balances - monthly
  

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Interconnection of GAW and EI: Critical Points
The accompanying waybill and the electronic invoice are inextricably linked in the system.

Automatic Cancellation
If a GAW is rejected or revoked, the EI issued on its basis is automatically cancelled. This occurs without any additional actions on the part of the taxpayer.

The Problem of Deadlines
When an EI is cancelled, there is a risk of violating the deadline for issuing a new document (15 calendar days from the date of the transaction).

Protective Mechanism
Clause 30-3 of the Rules creates an exception: when a GAW is rejected by the recipient after the established deadline, a new GAW and EI are issued within 3 business days from the date of rejection.

Practical Example

• Goods shipped on March 1
• GAW issued on March 1
• EI issued on March 5
• Recipient rejected the GAW on March 25 (after the 20-day deadline)
• The supplier must issue a new GAW and EI by March 28
• In the new EI, the transaction date remains March 1
  

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Practical Recommendations: How to Avoid Problems

Checklist for Safe Work with GAW
Daily control:

• Check the statuses of all GAW issued during the day.
• Monitor rejected documents.
• Record GAW received from suppliers.
  

Weekly control:

• Reconcile virtual warehouse balances with actual balances.
• Analyze GAW that are approaching the deadline for revocation.
• Verify the correctness of data for new counterparties.
  

Before each shipment:

• Verify the recipient's BIN (active / liquidated).
• Check the presence or absence of a warehouse ID (not critical, but useful to know).
• Verify the correctness of HS codes and product names.
• Ensure the quantity matches the actual availability.
  

Algorithm Upon Receiving GAW from a Supplier

GAW Status	Recipient's Action	Deadline
Data is correct	Confirm	Immediately or within the period established by the contract
An error is detected	Reject with reason stated	Before the confirmation period expires
Error noticed after confirmation	Coordinate revocation with the supplier	Within 20/10 days

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Analysis of Complex Situations

Situation 1: Counterparty requires indicating the ID of their warehouse, but the warehouse is not registered
Solution: Explain the mechanism of the unallocated warehouse to the counterparty. If necessary, request an official clarification from the SRC (State Revenue Committee).

Situation 2: The revocation period has expired, but an error has been discovered
Solution: It is no longer possible to correct the error. Prepare for a fine and, if necessary, submit revised tax returns. Learn lessons and strengthen control.

Situation 3: The recipient unreasonably rejects the GAW
Solution:

1. Document the fact of unreasonable rejection (correspondence).
2. Issue a new GAW within 3 business days.
3. File a complaint with the tax authority regarding the counterparty's actions.
   

Situation 4: Imported goods from the EAEU, GAW has been issued, but revocation is impossible
Solution: Accept the impossibility of correction. Conduct all checks at the stage of preliminary control before issuing the GAW.

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Judicial Practice and Official Clarifications

Position of the SRC on Deadlines (Response No. 721517 dated 13.01.2022)
When a GAW is rejected by the recipient after the established deadline, the special 3-day period for issuing a new GAW and EI applies. The general 15-day period for issuing an EI does not apply in this case.

Position on Retail Trade (Response No. 705669 dated 29.09.2021)
It has been confirmed that there is no obligation to issue a GAW when selling goods in retail trade to end consumers.

Changes as of April 1, 2023 (information from the NCE "Atameken" — National Chamber of Entrepreneurs "Atameken")
Significant reduction in the list of goods subject to mandatory GAW issuance. For most goods, issuance has become voluntary.

Administrative Practice
The most frequent violations identified by tax authorities:

• Absence of a GAW when there is turnover
• Discrepancy between data in the GAW and actual data
• Missing deadlines for corrections
• Unreasonable rejection of GAW by recipients
  

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Integrated Approach to Risk Management
Control System: Minimum Requirements

Control Element	Frequency	Responsible Person
Monitoring of GAW statuses	Daily	EI Operator
Reconciliation with virtual warehouse	Weekly	Accountant
Analysis of approaching deadlines	Weekly	Accountant
Inventory of balances	Monthly	Storekeeper + Accountant
Staff training	Upon changes	Manager

Technical Automation Tools

• Setting up automatic notifications in 1C about approaching deadlines
• Using the EI IS API for regular status extraction
• Implementation of electronic document flow with counterparties
  

Corporate Standards

• Establish in contracts with counterparties the obligation to promptly confirm/reject GAW
• Set internal deadlines for GAW verification (for example, 5 business days instead of 20)
• Designate responsible persons for each stage of goods and document movement
  

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Final Conclusions and Recommendations

1. Mandatory nature of GAW has been preserved only for a limited list of goods: excisable products, certain types of equipment, import/export to the EAEU, and grain crops.
2. Temporal priority: GAW must be registered before the physical movement of goods begins.
3. Error = non-reflection of turnover: The tax authority interprets the absence of a correct GAW as the absence of a sale, with all resulting consequences.
4. Correction deadlines are strict: 20 business days for transport by road, rail, air; 10 calendar days — without transport.
5. Financial penalties are significant: Up to 200 MCI with confiscation of goods and income for excisable products.
6. Virtual warehouse requires control: Unallocated warehouse is the norm, not an error.
7. GAW-EI linkage is critical: Cancellation of a GAW automatically cancels the EI.

Top-Level Practical Advice: Implement the "Triple Control" principle in your company — before shipment, the document is checked by the manager, the accountant, and the storekeeper. Only after three (virtual) signatures does the goods leave the warehouse. This is the only way to guarantee the absence of errors in the GAW system and avoid fines.

The tax system of the Republic of Kazakhstan provides a special mechanism for collecting corporate income tax (CIT) on income received by foreign legal entities from Kazakhstani sources. This responsibility is imposed on local counterparties acting as tax agents.

The essence of the tax agent institution
A Kazakhstani organization paying income to a foreign individual is granted tax agent status. This means it acts as an intermediary between tax authorities and the non-resident: it calculates the tax amount, withholds it from the payment due to the counterparty, and transfers it to the state budget. This arrangement ensures tax collection in situations where the direct recipient of the income has no physical presence in the country and is not subject to the jurisdiction of Kazakhstani regulatory authorities.

It is important to immediately draw a clear line between the two fiscal instruments. 

• Traditional corporate income tax on business income is regulated by the general provisions of the Tax Code and is paid by the taxpayer himself from net profit.
• In contrast, corporate income tax at the source of payment is a mechanism for guaranteed tax receipts into the budget during cross-border settlements and is regulated by a special section of the code (Articles 644–648 of the Tax Code of the Republic of Kazakhstan as amended until 2026; from 2026 – Articles 679–685 of the new Tax Code of the Republic of Kazakhstan).
  

With the beginning of the 2026 fiscal year, the legal regulation of this area has been radically updated: the Tax Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII ZRK has come into force. This document systematizes the key changes and offers a practical algorithm of actions for companies making payments to foreign partners.

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Regulatory framework and basic guidelines

Triggers for the emergence of tax liabilities
According to the provisions of Article 683 of the Tax Code of the Republic of Kazakhstan, any income of a foreign company originating in Kazakhstan is subject to corporate income tax immediately upon payment, provided that the non-resident's activities do not create a permanent establishment in the country.

A critical detail: the tax base is calculated based on the gross income. Any expenses incurred by the foreign counterparty do not reduce the tax base.

Subject composition of tax agents
The legislator assigns the function of withholding and transferring taxes to a wide range of taxpayers:

Category agent	Examples
Residents of the Republic of Kazakhstan	LLP, JSC, state institutions
Sole Proprietors	Sole Proprietor with a patent or generally established regime
Non-residents operating in the Republic of Kazakhstan	Foreign companies operating through structural divisions
Payers for asset transactions	Persons paying income from capital gains (except for stock exchange transactions)
Specialized service companies	Participants in assignment programs in the banking sector

Extraterritoriality of application of norms
The rules for withholding corporate income tax apply regardless of:

• Geographical location of payment;
• Settlement currencies;
• The actual manager of the funds (the non-resident himself or a third party on his behalf).
  

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Classification of taxable income
Detailed register of sources
The legislator identifies 39 categories of income recognized as received from Kazakhstan. For practical purposes, it is advisable to group them:

Operating revenues:

• Sale of commercial products on the domestic market of the Republic of Kazakhstan;
• Export operations with goods physically located in Kazakhstan;
• Performance of work and provision of services within the country;
• Provision of consulting, management, IT, marketing, legal and engineering services (even if the contractor is located abroad).
  

Passive income:

• Dividend payments from Kazakhstani issuers;
• Interest income on loans, credits and debt securities;
• Payments for the use of intellectual property (royalties);
• Insurance premiums and reinsurance contributions;
• Income from international transport;
• Increase in the value of assets upon sale.
  

Specific categories:

• Income of beneficiaries from jurisdictions with preferential tax regimes;
• Income in the form of unfulfilled advance obligations;
• Proceeds from the assignment of rights of claim in favor of residents.
  

Taxation limits: services abroad
Income received from activities carried out exclusively outside of Kazakhstan is exempt from taxation in the Republic of Kazakhstan.

Exceptions to the rule:

1. Services directly listed in paragraphs 3-5 of paragraph 1 of Article 679 of the Tax Code of the Republic of Kazakhstan (management, consulting and other specific types).
   

According to subparagraphs 3–5 of paragraph 1 of Article 679 of the Tax Code, such services include:

• management functions;
• consulting support;
• engineering, marketing, auditing, legal and financial services.

For these categories of services, the geographic location of provision is irrelevant – the tax liability arises due to the very nature of the activity.

Unconditional taxation of income from preferential zones
Clause 2 of Article 646 of the Tax Code of the Republic of Kazakhstan establishes a mandatory rule: income received from persons registered in states with preferential taxation (the list was approved by Order of the Minister of Finance of the Republic of Kazakhstan dated 08.02.2018 No. 142) is taxed at a fixed rate of 20%, regardless of the type of income and the place of provision of services.
The key implications of this provision are:

• Reduced rates do not apply to royalties, dividends or international shipments;
• The possession of a residency certificate does not give the right to apply the provisions of international treaties;
• The tax is calculated on the gross amount of income without the right to deduct expenses.
  
  

Case Study: Shipping from Hong Kong
Let's consider a typical situation. A counterparty from Hong Kong (a jurisdiction included in the list of preferential zones) provides international shipping services to a Kazakhstani company. The foreign partner provides a valid residency certificate.
Despite the existence of the document and the fact that the base rate for international shipments is 5%, the Kazakhstani tax agent is obligated to apply a 20% rate. The reason: the income recipient is registered in a state with preferential taxation, which prevents the application of both standard reduced rates and preferences under international agreements.

2. Income Attributable to a Permanent Establishment of a Non-Resident in Kazakhstan
Allocation of Income Under Hybrid Contracts
When concluding mixed contracts that provide for the fulfillment of obligations both in the Republic of Kazakhstan and abroad, the tax agent is obliged to ensure a documented and substantiated allocation of the contract value.

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CIT tariff schedule for 2026

3.1. Basic tax rates (Article 682 of the Tax Code of the Republic of Kazakhstan)

Type income	Applicable bid
General income (not specified separately)	20%
Insurance premiums (direct risk insurance)	15%
Insurance premiums (reinsurance)	5%
International transportation	5%
Dividends, interest, royalties, capital gains (standard)	15%
Interest on loans and debt securities	10%
Выигрыши от азартных игр и пари	10%
Income of recipients from offshore zones	20%

Innovation 2026: Progressive Scale
The new Code introduced a differentiated approach to two categories of payments:

A) Dividends to qualified participants (share ≥ 25%)

• Up to 230,000 MCI (994.75 million tenge with MCI=4,325 tenge): 5%
• Above the threshold: 5% of the base + 15% of the excess amount
  

B) Income of non-resident employees (clause 3, article 693 of the Tax Code of the Republic of Kazakhstan)

• Up to 8,500 MCI (36.76 million tenge): 10%
• Above the threshold: 10% of the base + 15% of the excess amount
  

3.3. Preferential regimes and international agreements

• Subjects of Art. 17 of the Tax Code of the Republic of Kazakhstan: For certain categories of organizations (for example, for transactions with shares), a preferential rate of 5% is established.
• Priority of international treaties: If there is a valid double taxation agreement (DTA), the taxpayer has the right to apply the reduced rate provided for in the agreement, subject to confirmation of the counterparty's residency.
• Scope: The provisions of Article 682 do not apply to the income of permanent establishments of non-residents; such income is declared in the general manner.
  

The MLI Convention: New Realities of International Tax Law
Since January 1, 2021, the Republic of Kazakhstan has been implementing the provisions of the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). This instrument is aimed at combating the abuse of international treaties for tax evasion.

Practical significance of the MLI: The Convention introduces a test of the principal purpose ( Principal Purpose Test), which allows for the refusal to apply benefits if one of the main purposes of the transaction or structure was to obtain tax benefits.

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Mechanics of calculation and retention

Time points of occurrence of obligations
Article 683 of the Tax Code of the Republic of Kazakhstan differentiates the withholding procedure depending on the status of the payment:

1. Actual income paid: Tax is subject to withholding strictly on the day of transfer of funds to a non-resident.
2. Accrued but unpaid income (deductible): Withholding is made within the deadline for filing the annual corporate income tax return - no later than March 31 of the year following the reporting year.
   

Payment option through agent
The legislator allows for a scenario in which a tax agent transfers the tax amount from their own funds, without withholding it from the recipient's income. In this case, the agent's obligations are considered properly fulfilled.

Calculation formula: CIT amount = Tax base (gross income) × Rate under Article 682 of the Tax Code of the Republic of Kazakhstan. Note: reducing the base by the expenses of a non-resident is prohibited by law

Retention mechanism: step-by-step algorithm
The procedure for calculating and transferring corporate tax for a non-resident includes the following steps:
Income identification Determine whether the payment falls under the list of income from sources in the Republic of Kazakhstan in accordance with Article 644 of the Tax Code of the Republic of Kazakhstan.
Step 2. Check the counterparty's status. Determine the recipient's country of registration, check the presence of a permanent establishment in Kazakhstan and the status of the jurisdiction (whether it is included in the list of preferential zones).
Step 3: Determine the applicable rate Apply the base rate (20%, 15%, or 5%) or the treaty rate if you have a valid residence certificate and there are no MLI restrictions.
Step 4. Calculating the Tax Amount Calculate the tax based on the gross income. Remember: non-resident expenses do not reduce the tax base.
Step 5. Withholding and transfer Withhold the calculated amount from the payment to the counterparty and transfer the tax to the budget within the specified period (no later than 25 days after the month of payment).

Numerical example
Foreign company LLP “B” performed engineering work for Kazakhstani LLP “A” in the amount of 100 conventional units.

• Applicable rate: 20% (general services);
• CIT amount: 100 USD × 20% = 20 USD;
• Amount to be paid to a non-resident: 100 USD - 20 USD = 80 USD;
• Amount to be transferred to the budget of the Republic of Kazakhstan: 20 USD.
  
  

Thus, the Kazakhstani company fulfills its obligations as a tax agent by transferring the fiscal portion directly to the state.

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Reporting regulations
Data presentation format
The mandatory reporting instrument is Calculation Form 101.04 “Corporate income tax withheld at source of payment from non-resident income”.

Reporting calendar

Reporting period	Deadline filing Form 101.04
I, II, III quarters	By the 15th day of the second month following the quarter
IV quarter (annual)	Until March 31 of next year

Communication channels with fiscal authorities

• Web portal "Taxpayer Cabinet" (knp.kgd.gov.kz);
• Mobile ecosystems e-Salyq Azamat / e-Salyq Business;
• Integrated external ERP systems;
• Traditional submission through PSCs (Public Service Centers) or tax authorities (paper format).
  

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Logistics of payments to the budget

Standard transfer terms

Base payment	Limit term payments
Paid income	25 calendar days after the month of payment
Advance payments	25 days after the month of accrual of income within the advance payment
Obligations resident before non-resident	25 days after the month of income accrual

Specifics of unpaid income
For amounts included in deductions, but not actually transferred to the counterparty, a special deadline is established: no later than 10 days after the deadline for filing the corporate income tax return.
Exception: Debt securities and deposits with a maturity outside the specified period are subject to the general rule (25 days).
Currency conversion
To convert liabilities into tenge, the official exchange rates of the National Bank of the Republic of Kazakhstan are used:

• For actual payments - on the payment date;
• For accrued but unpaid amounts - on the last day of the tax period;
• For advances - on the date of income accrual.
  

Geography of payment
Payment is made at the place of tax registration of the tax agent.

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Administration and compliance

Fiscal control instruments
State revenue authorities apply in-depth desk monitoring of Form 101.04, including:

• Cross-validation with data from the National Bank of the Republic of Kazakhstan on cross-border foreign exchange transactions;
• Verification of the correctness of the calculation of the tax base and the application of rates;
• Audit of the validity of the application of benefits under international treaties;
• Control over the completeness of VAT calculation for a non-resident (if there is an object).
  

Sanction risks
Identification of violations entails:

• Accrual of penalties for each day of delay;
• Additional assessment of taxes and fines;
• Reputational costs and increased scrutiny from regulatory authorities.
  

Checklist for risk minimization

• Regularly update the rate directories in the accounting systems;
• Request residency certificates before income is paid;
• Implement internal control over payment and reporting deadlines;
• Document the methodology for distributing revenue under mixed contracts.
  

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Evolution of regulation: a comparative overview

2026 Change Map

Parameter	Edition until 2026	Edition from 2026
Income standard	Art. 644	Art. 679
Rates regulation	Art. 646	Art. 682
Dividends (qualified participant)	Fixed 15%	Progression: 5% / 5%+15%
Interest on loans	15%	10%
Salaries of non-residents	15%	Progression: 10% / 10%+15%
Control of foreign exchange transactions	Selective	Systemic (integration with the National Bank of the Republic of Kazakhstan)

Invariant elements

• Basic rate of 20% for unspecified income;
• The principle of "tax on gross income" (without deducting expenses);
• Institutional role of the tax agent;
• Key categories of taxable income.
  

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Workshop for tax agents
Step-by-step work algorithm

1. Income identification: Reconciliation with the list in Article 679 of the Tax Code of the Republic of Kazakhstan. Exclusion of non-taxable transactions (services abroad outside the special list).
2. Checking the counterparty status: Establishing the presence/absence of a permanent establishment in the Republic of Kazakhstan.
3. Rate selection: Application of table 682, taking into account progressive scales for dividends and salaries.
4. Verification of an international treaty: Request and verification of a residency certificate for the application of a preferential rate under the DTT.
5. Liability calculation: Multiply gross income by the selected rate.
6. Payment execution: Transfer to the budget within a 25-day window.
7. Reporting: Timely filing of Form 101.04 in the prescribed format.
   

Register of typical errors

Error	Consequence	Preventive measure
Ignoring the progressive dividend scale	Additional accrual tax + penalties	Automate calculations taking into account the share of participation
Application of double tax treaty (DTT) benefits without a certificate	Penalty for unjustified reduction of obligations	Introduce the rule: "no certificate, no benefit"
Pass term payments	Penalty for each day of delay	Integrate the tax calendar into ERP
Misclassification of the place of provision of services	Underpayment tax	Conduct a legal analysis of the contract before payment
Delay in filing 101.04	Administrative fine	Assign personal responsibility for reporting

Working under the general regime requires submitting a comprehensive set of reports. To avoid confusion, we'll divide them into mandatory and special reporting.

Mandatory reporting (for everyone without exception)

1. Annual profit report (Form 100.00)
This document summarizes the company's financial activities for the year. It shows all revenues and all confirmed expenses. The final corporate income tax amount is calculated based on this declaration.

• Deadline: March 31st of next year.
• Important: By this deadline, you must be prepared not only to submit the report, but also to close all supporting primary documents.
  

2. Quarterly salary report (Form 200.00)
Every quarter, the company reports to the state on its employees' income. Form 200.00 combines two payments: the individual income tax (IIT), which is withheld from employees' salaries, and the social tax, which the company pays on top.

• Deadlines:
  
  • January-March → May 15
  • For April-June → August 15
  • For July-September → November 15
  • For October-December → February 15
    

Activity-based reporting

1. If you work with VAT (F. 300.00)
Registration for VAT can be voluntary or mandatory when turnover exceeds 20,000 MCI per year. Electronic invoicing is mandatory for VAT payers.
Submission deadline for 300.00: By the 15th of the second month after the quarter (same dates as for form 200.00, but shifted by a month: May 15, August, November, February).

2. If there is property (F. 700.00)
If a company has buildings, structures, or vehicles on its balance sheet, it must pay property tax.

• The system here is two-stage: first, at the beginning of the year, a preliminary calculation (701.00) is submitted to pay advances, and at the end of the year , a final declaration (700.00) is submitted.
• Annual declaration deadline: March 31.
  

3. If there are excisable goods (F. 400.00)
This is specialized reporting for producers and importers of alcohol, tobacco, and fuel.

Reality Check: How to Avoid Fines
Starting in 2026, tax controls will become even stricter. Key risks for businesses:

1. Data discrepancy in the electronic invoice. If you recorded a purchase from a non-resident on form 300.00 but cannot confirm tax payment, the system will detect this.
2. Salary discrepancies. If the 200.00 form indicates salary, but social security payments are incomplete or late, this is grounds for a desk audit.
3. Late payment. Any missed deadline will result not only in a fine of 15-30 MCI, but also in account blocking if the delay exceeds 10 business days.
   

A one-sheet reminder of deadlines:

Report Type	Reporting Period	Deadline
F. 100.00 (CIT)	All last year	March 31
F. 200.00 (IIT+ST)	Quarter	May 15 / Aug 15 / Nov 15 / Feb 15
F. 300.00 (VAT)	Quarter	May 15 / Aug 15 / Nov 15 / Feb 15
F. 700.00 (Property)	All last year	March 31

Tip: Don't rely on memory or old templates. It's better to set up a calendar in 1C or other accounting software once, which will remind you when reporting dates approach. And always check the current MCI for the current year—many calculations and thresholds depend on it.

When accruing income to employees in 2026, a Limited Liability Partnership acts as a tax agent and is obliged to make the following deductions and transfers to the budget:

1. Individual Income Tax (IIT) — 10% / 15%. As of 2026, a differentiation of rates has been introduced: the standard 10% applies to an employee's annual income within 8,500 MCI. If the total income for the year exceeds this threshold, an increased rate of 15% applies to the excess amount.
2. Mandatory Pension Contributions (MPC) — 10% (withheld from the employee's income).
3. Employer Mandatory Pension Contributions (EMPC) — 3.5%. This payment, introduced in 2024, has become firmly established in tax practice; in 2026, its rate remains at 3.5% of the payroll fund.
4. Social Contributions (SC) — 5% (paid from company funds).
5. Employer Contributions to CSHI (EC-CSHI) — 3% (at the employer's expense).
6. Employee Contributions to CSHI (E-CSHI) — 2% (withheld from the employee's income).
   

Total Burden on Business
In 2026, the total volume of obligations to the budget generated by one employee reaches 33.5%. It is important to understand the structure: IIT, MPC, and E-CSHI are covered by the employee themselves (withheld from the "gross" salary), while EMPC, SC, and EC-CSHI are direct expenses of the company and are accrued on top of the established salary.

Payment Regulations
The transfer of all taxes and social payments is made by the agent monthly. The deadline is the 25th day of the month following the reporting month. For example, obligations for March must be paid by April 25.

Taxation specifics depending on the employee's status

• Foreign Employees (Non-Residents): If a specialist is not a resident of the Republic of Kazakhstan, the calculation algorithm changes. MPC and SC are not provided for such individuals. However, as of 2026, for non-residents receiving income from sources in Kazakhstan, the IIT rate is set at 20%. The final percentage of deductions in this case is calculated individually, based on the priority of the 20% IIT rate over the abolished pension contributions.
  
• Holders of Temporary Residence Permit: Non-residents who have obtained a temporary residence permit in the Republic of Kazakhstan are treated as residents. For them, taxation is carried out according to the full range of obligations (standard rates of IIT, MPC, SC, etc.).
  
• Civil Law Contracts: Remuneration under civil law contracts is also subject to pension contributions (MPC — standard 10%). With regard to health insurance, contributions to CSHI (2% and 3%) are paid in the general manner, without any exceptions for contract agreements.
  

Transformation of tax deductions for individual income tax in 2026
With the entry into force of the new Tax Code on January 1, 2026, the mechanism for reducing taxable income has undergone fundamental changes.

• New Deduction Standard: Residents of Kazakhstan have received the right to apply a monthly basic tax deduction in the amount of 30 MCI.
  
• Digital Expression: Given that the MCI for 2026 is set at 4,325 tenge, the monthly non-taxable minimum for IIT calculation is 129,750 tenge.
  
• Important Change: The previous deduction mechanism (14 MCI or 1 MW) has completely lost force as of 2026 and is no longer applied.
  

General corporate standards
The head of the company (Director) is a full-fledged employee under labor legislation. In this regard, even if the director is the sole founder, the LLC is obliged to accrue wages to them. Their amount cannot be lower than the minimum level established by law (MW = 85,000 tenge in 2026), and from the income paid, the entire list of taxes and contributions provided for ordinary employees must be calculated and paid.

Turnover Balance Sheet (TBS), Subconto Analysis, Status of Accounts Receivable and Accounts Payable — these are the foundation upon which reliable company reporting is built. Errors in these data lead to distortion of the tax base, cash gaps, and conflicts with counterparties.
In Kazakhstani practice, there is no single law requiring reconciliation "every Friday." However, there are professional standards and tax risks that dictate a clear frequency of control procedures. Below is an expert analysis of how often and why reconciliation should be carried out in the realities of the Republic of Kazakhstan.

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1. Turnover Balance Sheet (TBS): Frequency of Control
Recommendation: Monthly, no later than the 5th day of the following month.

TBS is a snapshot of all accounting accounts. If you look at it once a quarter, you risk discovering an error that can no longer be corrected "retroactively" without distorting the quarterly reporting.

Why monthly?

• VAT control (EI). In Kazakhstan, there is a strict linkage to electronic invoices. If the balance in the TBS for accounts 1420, 3130, or 3000 does not match the data of the EI information system, this is a signal for immediate verification. Waiting until the end of the quarter is dangerous — the discrepancy may accumulate.
• Payroll taxes. Payroll calculation and settlements with the payroll fund (accounts 3350, 3210) require monthly reconciliation, as social payments have different payment deadlines.
• Currency revaluations. Regardless of whether there was any flow on the currency account, a revaluation must be performed at the end of the month (accounts 1030, 1040). Exchange rate differences are recorded as income or expenses (account 6250 or 7430). If you do not reconcile the TBS monthly, you may miss the moment and fail to reflect these differences in the period to which they relate.
  

Expert advice: Set up automatic generation of TBS in 1C on the 1st day of each month. Reconcile the total turnovers with reports on sales and bank receipts. Pay special attention to accounts 1210 (short-term receivables) and 3310 (short-term payables) — these are risk areas regarding the statute of limitations.

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2. Subconto: In-Depth Analytics by Partners and Nomenclature
Recommendation: Quarterly, with in-depth verification before submitting Form 300.00 and Form 100.00.

Subconto is an analytical breakdown of your accounts (by counterparties, contracts, goods). Errors at this level lead to incorrect turnovers being "dropped" from the VAT declaration (300.00) or the register for acquired goods being filled out incorrectly.

When to sound the alarm?

1. Before the VAT quarter closing. Reconciliation of subconto for accounts 1420 (VAT to be credited) and 3130 (VAT payable) should be done by the 10th day of the second month after the quarter. That is, if the reporting period is Q1, all analytics should be perfect by May 10 in order to calmly submit Form 300.00 by May 15.
2. During inventory of inventories. For goods (account 1330) and materials, a discrepancy in subconto may mean that you sold something that is not in the warehouse or did not record a receipt. Minimum — a detailed reconciliation once every six months (before the annual inventory), maximum — monthly for critical items.
   
   

Expert advice: The most common errors in subconto are "stuck" advances (accounts 1610, 3510). If you transferred a prepayment to a non-resident, but the closing certificates will arrive in a month, the subconto should "remember" this advance. We recommend doing a quarterly analysis of accounts 1610 and 3510 to determine whether the advance has turned into hidden receivables or payables for which the statute of limitations has expired.

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3. Accounts Receivable (AR): The Art of Not Losing Money
Recommendation: Monthly monitoring + formal reconciliation once a quarter.

Accounts receivable is your money that is currently with counterparties. In Kazakhstani realities, where bankruptcies and liquidations of LLCs are frequent, you cannot afford to relax.

Two levels of reconciliation:

• Operational control (monthly). The accountant or financial analyst reviews account 1210 (short-term AR) and 1280 (overdue AR). Objective: to see growing balances and remind managers of debts.
• Legally significant reconciliation (quarterly). This refers to reconciliation reports of mutual settlements (RK form). Signing them with the counterparty once a quarter interrupts the running of the statute of limitations. In Kazakhstan, the general statute of limitations is 3 years. If the report is not signed, it will be impossible to collect the debt through court after 3 years.
  
  

Special cases for Kazakhstan:

• Non-residents. If you have AR from a foreign company, reconciliation should be carried out at least once every six months, taking into account currency fluctuations. Revaluation of such debt occurs at each reporting date.
• Doubtful debts. In Kazakhstani tax accounting, provisions (reserves) can be created for doubtful claims. To do this, you need to know exactly which portion of AR has been "stuck" for more than 90 days. Monthly monitoring allows you to create a reserve in a timely manner and optimize CIT.
  

Expert advice: Implement a procedure whereby the reconciliation report is automatically sent to the counterparty at the close of the quarter. A received signed report is not just a piece of paper, but a document that will protect you in court and before the tax authority when writing off a bad debt.

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4. Accounts Payable (AP): How to Avoid Incurring Fines
Recommendation: Monthly reconciliation for taxes and salaries + quarterly for suppliers.

Accounts payable is your debts. Here the main risks are missing a payment deadline and distorting tax reporting.

Priority areas for reconciliation:

• Tax AP (accounts 3100, 3110, 3120, 3130). Reconciliation should be done every month after submitting reports and making payments. The balance on these accounts should be zero after the payment is transferred. A remaining balance on account 3130 (VAT payable) a month after filing the declaration is an error.
• Salaries (account 3350). Reconciliation is carried out twice a month: upon accrual and upon payment. A remaining balance on account 3350 at the end of the month is either salary arrears or "stuck" deposited wages.
• Suppliers (account 3310). Quarterly reconciliation with the signing of reports is just as important as for receivables. This protects against a situation where the counterparty files a claim a year later, but the documents have already been lost.
  

Expert advice: Keep a separate control over accounts payable to non-residents (account 3320). When paying income to a foreigner, you are obliged to withhold CIT at the source of payment. If AP remains for a long time, you either cannot transfer the money (no currency) or risk missing the tax payment deadline. Monthly reconciliation for foreign currency counterparties is mandatory.

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Final Recommendations: "Roadmap" of Reconciliations
To systematize the process, we propose the following procedure (in the context of Kazakhstani accounting):

What We Check	How Often	Responsible Person	Purpose
TBS as a whole	Monthly (by the 5th day)	Chief Accountant	Control of double-entry, currency revaluation
Settlements with the budget (accounts 31xx)	Monthly (after payment)	Tax Accountant	Elimination of penalties and fines
Receivables (account 1210)	Quarterly (reports)	Accountant + Lawyer	Interruption of statute of limitations, reserves
Payables (account 3310)	Quarterly (reports)	Settlement Accountant	Confirmation of debt, elimination of claims
Advances (1610, 3510)	Quarterly	Accounting Accountant	Closing of prepayments, cleanliness of subconto
Reconciliation with EI (VAT)	Monthly	EI Operator	Matching of turnovers in the database and in accounting
Inventories (warehouse)	Quarterly / Annually	Storekeeper, Accountant	Elimination of shortages and surpluses

Main principle: do not postpone error detection until the end of the year. In Kazakhstani practice, the tax authority often disallows CIT deductions if it cannot trace the supplier "chain" or debt confirmation. Regular quarterly reconciliation is the minimum standard of financial hygiene that will protect the business from additional assessments and legal disputes.

Digitalization of labor relations in Kazakhstan has reached a level where the Enbek.kz portal (Unified System for Recording Employment Contracts — USREC) has become not just a job search platform, but a fully-fledged tool for recording personnel events. Employers are required to enter data on employee movements here, but until recently, there was confusion regarding civil law contracts. Let us examine what needs to be registered and when, based on the latest clarifications from the Ministry of Labor.

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1. Mandatory Registration: Everything Related to Labor Relations
According to paragraph 2 of Article 23 of the Labor Code of the Republic of Kazakhstan, the employer is obliged to enter into the USREC information on:

• the conclusion and termination of an employment contract;
• all changes and amendments thereto;
• the termination of the employment contract.
  
  

Who is subject to registration?
This rule applies to all employees with whom an employment contract has been concluded. This includes:

• Ordinary employees hired under employment contracts.
• The director of the enterprise, even if they are the sole founder. In this case, an employment contract as a separate document may not be concluded (paragraph 2 of Article 140 of the Labor Code of the Republic of Kazakhstan), but the director is obliged to issue an order on assuming office based on the participant's decision. Information from this order (start date of work, term of activity, place of work) is entered into the USREC in the general manner.
• Part-time and temporary workers.
  

Which specific changes need to be entered?
The following are subject to registration:

1. Hiring — initial entry of data on the conclusion of the contract.
2. Changes in working conditions — transfer to another position, changes in pay, work schedule, transfer to another structural unit. All amendments recorded in the additional agreement to the employment contract must be reflected in the system.
3. Personnel movements that do not significantly change the terms of the contract but are important for record-keeping.
4. Leaves — according to clarifications, the system is also intended for recording information on employee leaves.
5. Termination of the employment contract — dismissal of an employee must be registered immediately.
   

Why is this important?
Failure to enter data in a timely manner or the absence of such data is a violation of labor legislation. For the employer, this is fraught with fines during inspections. For the employee — problems with confirming work experience, calculating pensions, and social benefits.

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2. Civil Law Contracts: To Register or Not? (Official Position)
For a long time, this issue caused disputes, especially after the "Civil Law Contracts" tab appeared in employers' personal accounts on Enbek.kz, and some entrepreneurs began receiving notifications requiring them to register such contracts.

Official Response from the Ministry of Labor

In November 2025, the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan provided a comprehensive clarification: registration of civil law contracts (CLC) on the Enbek.kz portal is not mandatory.

Legal Justification

• Different nature of relationships. An employment contract (governed by the Labor Code of the Republic of Kazakhstan) implies that the employee is included in the staff, follows internal work rules, and receives a salary for the process. A CLC (governed by the Civil Code of the Republic of Kazakhstan) is a relationship between a client and a contractor — equal parties — where the result is what matters.
• Scope of the USREC. The Unified System for Recording Employment Contracts was created specifically for recording labor relations. There are no legal grounds to extend its application to civil law transactions.
  

So why did the tab appear?

The appearance of CLC functionality in the system is related to the state's plans to create a "complete employment history of citizens." In the future, there will likely be an option to voluntarily reflect such contracts so that citizens can develop a more complete digital profile. However, as the Ministry of Labor emphasizes, at present this is a right, not an obligation of the employer.

The Main Risk When Working with CLC

Despite the absence of an obligation to register a CLC, the employer must be extremely attentive to its content. If, during an inspection by the labor inspectorate or tax authority, it is determined that a CLC is actually disguising an employment relationship (regular payments, fixed schedule, subordination to work rules, provision of a workplace), it will be reclassified as an employment contract. The consequences — additional tax assessments, fines, and the obligation to retroactively enter this employee into all accounting systems, including the USREC.

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3. Practical Recommendations for Employers
To avoid problems with personnel records on the Enbek.kz portal, follow this procedure:

1. Clearly distinguish between contracts
   
   • If a person works on a permanent basis, follows a schedule and company rules — an employment contract is concluded with them, which must be registered in the USREC.
   • If you hire a contractor for a one-time task (write an article, make repairs, conduct an audit) — execute a CLC. There is no need to register it on Enbek.kz.
     
2. Observe deadlines
   Information about hiring or changes in working conditions must be entered into the system in a timely manner. Delaying registration may be deemed a violation.
   
3. Do not forget about the director-founder
   Even if the director is also the business owner and does not write leave applications, their appointment (assumption of office) must be recorded in the USREC based on an order.
   
4. Monitor updates
   Legislation in the field of labor digitalization is dynamic. The functionality for "voluntary registration of CLC" may be introduced in the near future. We recommend following official clarifications from the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan, rather than relying on rumors and calls from suspicious individuals.
   

Summary

Type of Contract	Is Registration on Enbek.kz Mandatory?	Basis
Employment contract (including with the director)	YES, mandatory	Article 23 of the Labor Code of the Republic of Kazakhstan
CLC (contracting, services)	NO, no obligation (voluntary registration may be possible in the future)	Clarification of the Ministry of Labor, Article 1 of the Labor Code of the Republic of Kazakhstan

Tax Code of the Republic of Kazakhstan, effective from 2026, offers businesses a tool that changes the traditional logic of depreciation. This refers to the right of the taxpayer to a one-time deduction of capital expenditures — an alternative to the extended write-off of asset values over time.

Economic Logic of the Mechanism
Unlike classic depreciation, where the cost of a fixed asset is amortized in installments over its useful life, the investment preference allows expenses to be recognized entirely in the period when the asset is put into operation. For a company, this means a significant reduction in current CIT liabilities and the release of working capital.

Assets Subject to the Preferential Regime
The legislator has established a clear list of assets for which the application of a 100% deduction is permitted:

• Capital structures (production buildings and facilities);
• Technological equipment and production lines;
• Intangible assets in the form of software and rights thereto.
  

Critical Conditions for Recognizing the Deduction
The practical application of the preference requires careful attention to the formal criteria set forth in Article 283 of the Tax Code. Failure to comply with any of them may become grounds for additional tax assessments:

1. Accounting discipline. The asset must be correctly classified in accounting — as a fixed asset, investment property, or intangible asset in accordance with IFRS.
2. Localization of the asset. Property (except for movable assets and software) must be located on the territory of Kazakhstan.
3. Production orientation. The use of the asset must be inextricably linked to income-generating activities.
4. Exclusion of double benefits. Application of the preference is not permitted if other tax benefits have already been used for the same asset (for example, under an investment contract).
5. Correct valuation. The initial cost is formed strictly according to accounting rules, net of costs that the Code directly excludes from deductions
   

What Is Important to Understand About the Moment When the Right to a Deduction Arises
The key feature: the right to a write-off arises at the moment the asset is recognized on the balance sheet and its initial cost is formed. The source of financing for the purchase — own funds, a loan, or installment payment — does not affect the possibility of applying the benefit.

Related Support Tools
In addition to the basic investment preference, the new Code introduces an additional incentive for innovation activity. R&D expenses may be written off with a multiplier factor of 300%, which creates more attractive conditions for companies developing their own technological solutions.
Thus, the tax innovations of 2026 provide businesses with flexible tools for managing the fiscal burden, but the effectiveness of their use directly depends on the quality of accounting processes and understanding of regulatory constraints.

Verifying your counterparties in Kazakhstan is a necessary step to protecting your business from financial and tax risks. Collaborating with an inactive or " sham " company may result in the denial of VAT credits and the invalidation of expenses.
To check whether a counterparty is on the list of unreliable taxpayers, you can use the following official and alternative sources.

Official sources from the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan
The most reliable way is to use the services directly from the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan (kgd.gov.kz).
For a comprehensive check, use the "Search for Unreliable Taxpayers" service.

• Search link: https://kgd.gov.kz/ru/services/taxpayer_search_unreliable
• What it checks: This service aggregates data across several key lists, including categories that interest you:
  
  1. Taxpayers recognized as inactive are companies that do not submit reports and do not carry out transactions on bank accounts.
  2. Taxpayers whose registration has been declared invalid are companies whose registration has been cancelled by court order.
  3. Taxpayers absent from their place of residence.
  4. Taxpayers reorganized in violation of the Tax Code.
     

A direct link to the list of companies with invalid registration is available here: https://kgd.gov.kz/ru/services/taxpayer_search_unreliable/list

The official list of sham enterprises is published on the State Revenue Committee's website by year. It is important to note that this data is updated as court decisions are issued. You can access it in a special section: https://www.kgd.gov.kz/en/section/perechen-lzhepredpriyatiy 

Important: Transactions with companies on these lists have significant tax consequences. VAT amounts from such transactions are not deductible, and expenses are not taxable.

Additional official information can be obtained through the Egov portal by ordering an electronic certificate from the state database "Legal Entities." This certificate will contain information about the company's inactivity status.

Alternative and commercial services
These services collect data from the same official sources, but often offer a more user-friendly interface and additional verification options in a single report.

• TSNIK.KZ: A free service that allows you to check your counterparty based on a variety of parameters, including whether they are listed as "sham enterprises " or "inactive." Registration is required, and there is a limit of 10 checks per day.
• Adata.kz: Provides detailed reports on legal entities and Sole Proprietors. The "Enterprise" section includes direct indicators: "List of ' Inactive' " enterprise '" (List of inactive enterprises) and "List of ' Fake enterprise '" (List of false enterprises).
• Kontur.Fokus: In reports on Kazakhstani companies, a "Special Registers" section is displayed, where you can see whether a counterparty is listed as a sham or inactive company, as well as the date it was added to the register and a link to the source.
  

Recommendations for verification
To minimize risks, it is recommended to conduct a comprehensive check:

1. Start with the free official "Search for Unreliable Taxpayers" service on the kgd.gov.kz website.
2. Check the counterparty against the list of fake companies on the same website.
3. Use alternative services to quickly check additional parameters (for example, tax arrears, the manager's participation in mass companies).
4. Check not only the company itself but also its director/founder for connections to other problematic legal entities. This can also be done through the State Revenue Committee's services or commercial platforms.
   

If you need assistance interpreting data for a specific counterparty or would like to learn about other aspects of the audit (e.g., tax arrears), please clarify your request.

Every business faces a situation where a counterparty fails to pay its invoices. The money appears to have been earned, the income is reflected in the financial statements, and taxes have been calculated, but there is no actual money in the account. Kazakhstan's tax legislation provides a mechanism for writing off such debts and reducing the corporate income tax (CIT) taxable base. The key is to correctly calculate the deadlines and gather evidence.

1. What debts can be considered "doubtful" for the tax authorities?
Not every debt you cannot collect automatically qualifies for preferential write-off. Article 248 of the Tax Code of the Republic of Kazakhstan sets clear criteria:
The following are subject to questionable claims:

• Debts of legal entities and sole proprietors arising solely from the sale of goods, works, and services. Loans, advances, and penalties (separately) are not included.
• Debts that have not been repaid within 3 years from the date the right of claim arose.
• Debts of any debtors (including individuals), if they are declared bankrupt in accordance with the established procedure.
  
  

Important note: If your debtor is a foreign company, its debt is considered doubtful only if the company operates in Kazakhstan through a permanent establishment or official branch. Debts of "virtual" non-residents with no ties to Kazakhstan are not covered by this article.

2. Three-year deadline: how to avoid missing the date
The most common risk for an accountant is misidentifying the year in which a deduction can be claimed. The Tax Code strictly ties deductions to a specific tax period.
Rules for calculating 3 years:

• The starting date is the date the claim arose. This is usually the date the goods were shipped, the certificate was signed, or the invoice was issued, which is when you recognized the income for tax purposes.
• The countdown is suspended if the debtor officially initiates bankruptcy proceedings, is in liquidation, or is placed into rehabilitation proceedings. During this period, the countdown is stopped.
• The end result: the right to a deduction only applies in the tax period (year) in which the three years expire. Not earlier (until the deadline has passed) and not later (the tax office will deduct the expenses if you claim the deduction next year).
  

Example from practice:
Company A shipped goods to Company B on May 15, 2023. The three-year period expires on May 15, 2026. Therefore, this debt can only be included in the deductions when filing the 2026 tax return (by March 31, 2027). If the accountant accidentally wrote it off in 2025, the tax office will assess additional corporate income tax, penalties, and a fine. If the accountant only remembered about it in 2027, the deduction will no longer be available.

3. How much can I write off? Limits and restrictions
Many entrepreneurs mistakenly believe that they can write off the entire debt, including late fees and penalties. This isn't entirely true.
Maximum deduction amount:

• The deduction is provided in an amount not exceeding the amount of previously recognized income from sales.
• If the debtor has made a partial payment (for example, paid 30%), only the remaining 70% (within the amount of the initial income) can be deducted.
• Fines, penalties, and interest accrued for late payment may also be included in the amount of the doubtful claim, but when combined with the principal debt, they cannot exceed the amount of the original income.
  

Example:
You sold equipment for 2 million tenge. The buyer didn't pay. Under the contract, you accrued a penalty of 200,000 tenge. The total debt is 2.2 million tenge. The maximum deductible amount is 2 million tenge (the initial income). The remaining 200,000 tenge in penalties is not deductible unless the penalty was part of the income recognized upon sale.

4. Counterparty bankruptcy: accelerated write-off procedure
If the debtor is officially declared bankrupt, there is no need to wait three years. This is a separate ground for declaring a debt doubtful, as provided for in paragraph 2 of Article 248 of the Tax Code of the Republic of Kazakhstan.
What is needed for confirmation:

1. Court decision to declare the debtor bankrupt.
2. A certificate or extract from the state electronic register of legal entities on the exclusion of a company from the register due to liquidation.
3. For Sole Proprietors - a certificate of deregistration as an Sole Proprietor.
   

Important: If bankruptcy proceedings are delayed and the debtor's assets are insufficient to pay off creditors, you have the right to write off the debt after the bankruptcy proceedings are completed, without waiting for formal exclusion from the register, but only if you have supporting documents from the bankruptcy or liquidation manager.

5. Documentation: what to require from an accountant
During an audit, the tax authorities will first request documents confirming the validity of the debt. Failure to do so will result in a 100% denial of the deduction.
Minimum package:

• Agreement with the debtor (the main document establishing obligations).
• Primary documents: invoices, consignment notes, certificates of completion of work/services.
• Reconciliation statements (preferably signed by both parties at least once within three years). A reconciliation statement is not required by law, but in legal disputes, it often becomes decisive evidence that the parties acknowledged the debt.
• A manager's order to write off a doubtful debt. The order must include the reason (expiration/bankruptcy), amount, date of occurrence, and references to supporting documents.
• An accounting statement confirming that the amount was previously included in income.
  
  

Advice: Keep this package for at least 5 years after writing it off. The tax authorities have the right to audit this period for 5 years (Article 93 of the Tax Code of the Republic of Kazakhstan).

6. The other side of the coin: if you write off the debt, but it doesn’t apply to you
If your company is a debtor and the creditor forgives your debt or you default on your obligations, you have obligations, not benefits.
Accounts payable (you owe):

• If the debt to the supplier is not repaid within 3 years from the date of its occurrence or the creditor is liquidated, this amount is recognized as a doubtful liability.
• Such liability is subject to inclusion in the total annual income (TAI) of the period in which the 3-year period expired or the creditor was liquidated.
• You will have to pay corporate income tax on this amount.
  

Debt forgiveness by mutual agreement
If you've agreed to debt forgiveness with a creditor, this also constitutes income for you (the debtor). For the creditor, it's a gratuitous transfer that's not deductible (Article 286 of the Tax Code of the Republic of Kazakhstan). Therefore, by signing a debt forgiveness agreement, you deprive the counterparty of the right to a deduction and create taxable income for yourself. If the statute of limitations has already expired, it's more advantageous to write off the debt after the expiration of the statute of limitations, rather than to formally declare it "forgiveness."

7. Risks and typical mistakes: how companies fail
An analysis of judicial practice and clarifications from authorized bodies shows that tax authorities most often remove deductions for doubtful debts in the following situations:

1. Period error. Write-off occurred before the end of 3 years or one year after the expiration date.
2. No connection to income. The debt arose not from sales, but, for example, from a loan issued or tax overpayment.
3. The counterparty is a " false enterprise" If the court determines that the transaction with such a counterparty was fictitious and no actual delivery took place, the deduction will not be granted.
4. Incomplete documentation. No contract, no documentation, no proof of shipment—the tax authorities will consider the expenses unjustified.
5. Advances issued. If you transferred an advance payment, didn't receive the goods, or the supplier disappeared, this is a loss, but not a dubious claim under Article 248 of the Tax Code of the Republic of Kazakhstan. Different rules apply for such cases.
   

8. 7. Step-by-step instructions: how to write off debt without losses

Stage	Action	Document	Checkpoint
1	Establish the date when the income under the transaction arose	Contract, waybill, invoice	The date = start of the 3-year period
2	Track the expiration of the 3-year period	Calendar, reconciliation reports	Date + 3 years = right to deduction
3	Check whether there were any interruptions of the period (bankruptcy, liquidation)	Court extracts, legal entity register	Suspension of the period extends the waiting time
4	Gather supporting documents	Contract, primary documents, reconciliation reports	Complete package on file
5	Issue a write-off order	Order of the head/manager	Indicate the basis and the amount
6	Reflect in accounting (expenses)	Accounting certificate	Account correspondence
7	Fill out declaration Form 100.00	Appendix to the declaration	The amount is included in deductions
8	Keep documents	The entire package	5 years after write-off

Summary: Checklist for Safe Write-Off

• The debt arose from the sale of goods/works/services.
• The income from this sale was recognized and reflected in tax accounting.
• 3 years have passed from the date of origin (or there is confirmation of bankruptcy).
• The contract, delivery notes/acts, and reconciliation reports (preferably) are available.
• An order from the head/manager on the write-off has been issued.
• The write-off occurs in the year when the statute of limitations expired (not earlier, not later).
• The amount of the deduction does not exceed the amount of previously recognized income.
  
  

Compliance with these rules will allow you to legally reduce the taxable base and avoid claims from tax authorities during audits.

The topic of confirming the source of funds for large purchases in Kazakhstan is becoming increasingly relevant due to the strengthening of financial control. According to the information provided, the threshold for special attention from the state is set at over 20,000 MCI.

What Does the Threshold of 20,000 MCI Mean?
20,000 MCI (Monthly Calculation Index) is the amount above which a purchase falls into the sphere of special attention of financial monitoring. It is important to monitor the current size of the MCI, as it changes annually.

• In 2026, this amount is approximately 86,500,000 tenge (based on an MCI of 4,325 tenge).
  

Important: This refers not to a one-time purchase, but to the total value of property acquired during the year. That is, if you buy an apartment for 50 million tenge and a car for 30 million tenge in the same year, the total amount of 80 million tenge will exceed the threshold and may raise questions.

How Does the Control Mechanism Work?
The state does not check every buyer manually. Control is exercised through second-tier banks. If the threshold is exceeded, banks are obliged to transmit the following information to the tax authorities:

• Data on the existence of bank accounts and their numbers;
• Information on balances and movement of funds in these accounts;
• Information on the buyer's income and property.
  
  

The purpose of such monitoring is to remotely identify discrepancies between a citizen's income and their large expenditures, as well as to reduce the shadow economy.

What Documents Will Confirm the Source of Funds?
Although the search results do not provide a direct list of documents, in practice tax authorities expect to see confirmation that the funds spent were accumulated or received legally. Here is a list of the main documents that may be required:

Category of Income	Supporting Documents
Official salary	Certificate from place of employment (Form 910.00), statements from salary account for the period of fund accumulation, Individual Income Tax declarations
Income from business	Declarations for sole proprietors or LLCs, statements from settlement accounts, contracts with clients
Sale of property	Purchase and sale agreement (for sold apartment, car, etc.), documents confirming receipt of money (receipt, bank transfer)
Inheritance or gift	Certificate of inheritance, gift agreement. Important: these documents must be notarized
Savings	Statements from deposit accounts in banks over a long period, showing the history of fund accumulation
Income from foreign sources	Declarations filed abroad, certificates from foreign employers, statements from foreign banks (with a notarized translation into Kazakh or Russian)
Income from investments	Contracts with brokers, statements on movement of funds in brokerage accounts, dividend checks
Income from property rental	Lease agreements, declarations and receipts for tax payment on this income

What Happens If You Cannot Confirm the Source of Funds?
If the tax authority, having received information from the bank, finds that your expenses significantly exceed your officially declared income, it may initiate a tax audit.

The procedure typically includes the following stages:

1. Notification. You will receive a notification asking you to explain the source of funds.
2. Tax audit. If explanations are not provided or are deemed insufficient, an audit is appointed.
3. Additional tax assessment and fines. Based on the audit results, Individual Income Tax (IIT) may be assessed on the unconfirmed amount, as well as fines and penalties.
4. Court collection. In case of non-payment, the materials are transferred to court for compulsory collection.
   

Summary
The main advice is to keep all documents that can explain the origin of your large savings. If you are planning a purchase worth more than 20,000 MCI (approximately 86.5 million tenge in 2026), take care in advance to have on hand bank statements, contracts, tax declarations, and other documents confirming the legality of your income. This will save you from potential problems with tax authorities in the future.

If you have questions about a specific situation or type of income, you can ask them in a follow-up request.

Revaluation of Fixed Assets — a tool that allows bringing the carrying value of assets to their real market price. However, in Kazakhstan, this tool creates a serious gap between accounting and tax accounting. If depreciation increases in accounting after revaluation, the tax inspectorate "does not see" this increase. Let's examine how to correctly account for these discrepancies and what obligations arise for the company.
1. Mandatory Revaluation from 2026: What Has Changed?
From January 1, 2026, the new Tax Code of the Republic of Kazakhstan came into force, which introduced significant amendments to the procedure for determining the tax base for property tax.
Article 591 of the Tax Code of the Republic of Kazakhstan establishes: the tax base for taxable objects (buildings, structures, residential premises) is determined as the average annual carrying value according to accounting data, taking into account the revaluation performed.
Key requirement: revaluation of property must be carried out at least once every three years.
Important Nuance for Those Who Account at Cost
If your accounting policy (in accordance with IFRS (IAS) 16) provides for the cost model (cost less depreciation and impairment), revaluation is not provided for within this model. However, the requirements of tax legislation oblige you to carry it out for the purposes of calculating property tax. This creates a conflict: accounting does not require revaluation, but tax law does.
Conclusion: even under the cost model, to comply with Article 591 of the Tax Code of the Republic of Kazakhstan, revaluation will have to be carried out. The three-year period begins in 2026.

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2. Accounting: Depreciation Increases After Revaluation
After a revaluation (revaluation upward), the carrying amount of the fixed asset in accounting increases. This entails a recalculation of depreciation charges.

How Is Depreciation Recalculated?
According to IFRS (IAS) 16, after revaluation, depreciation is calculated based on the new (revalued) amount and the remaining useful life.

Example:

• A machine was purchased for 1,000,000 tenge.
• Useful life — 10 years.
• Annual depreciation: 100,000 tenge.
• After 5 years (carrying amount 500,000 tenge), a revaluation upward was performed to a fair value of 800,000 tenge.
• Remaining useful life — 5 years.
• New annual depreciation: 800,000 / 5 = 160,000 tenge.
  
  

In accounting, depreciation increased from 100,000 to 160,000 tenge per year.

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3. Tax accounting: revaluation results are not recognized
This is where the main discrepancy lies. The Tax Code of the Republic of Kazakhstan is categorical: revaluation results are not taken into account for corporate income tax purposes.
Legal basis

• Article 268 of the Tax Code of the Republic of Kazakhstan: the value of a fixed asset in tax accounting is not increased by the revaluation value.
• Subparagraph 9) of paragraph 2 of Article 225 of the Tax Code of the Republic of Kazakhstan (2025) / subparagraph 8) of paragraph 1 of Article 238 of the Tax Code of the Republic of Kazakhstan (2026): income arising in accounting from revaluation is not considered as income for corporate income tax purposes.
• Clause 5 of Article 242 of the Tax Code of the Republic of Kazakhstan (2025) / Clause 6 of Article 257 of the Tax Code of the Republic of Kazakhstan (2026): expenses (depreciation) arising in accounting in connection with revaluation are not considered as deductions for corporate income tax purposes.
  

What does this mean in practice?

• Tax depreciation continues to be calculated from the original cost (or cost formed according to tax accounting rules without taking into account revaluation).
• The value balance of the fixed assets (FA) group is not increased by the amount of revaluation.
• CIT deductions remain at the previous level, despite the increase in accounting depreciation.
  

Example (continued):

• Tax cost of the machine (value balance of the group) — 500,000 tenge.
• Tax depreciation (for example, for Group III, the rate is 15%) — 75,000 tenge per year.
• Accounting depreciation after revaluation — 160,000 tenge.
  

Difference in depreciation: 160,000 - 75,000 = 85,000 tenge per year. This amount reduces the financial result in accounting, but for tax purposes, it does not exist.

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4. Temporary Differences and Deferred Tax: Theory and Entries
It is precisely because of such discrepancies that temporary differences (TD) arise. A temporary difference is the difference between the carrying amount of an asset in accounting and its tax base.
Taxable Temporary Difference
Upon revaluation (revaluation upward), the carrying amount of the asset in accounting becomes higher than its tax base. This is a taxable temporary difference. Why is it called that? Because in the future, when the asset is sold or when depreciation is "recovered" through income, this difference will "reverse" and increase taxable profit.
Deferred Tax Liability (DTL)
The taxable temporary difference is multiplied by the CIT rate (20%) and forms a deferred tax liability (DTL).
Formula:

DTL = Revaluation amount × CIT rate

Entries for Reflecting DTL
According to IFRS (IAS) 12, the deferred tax liability arising from revaluation is recognized in equity (capital), not as CIT expense.

Transaction Description	Debit	Credit	Explanation
Revaluation of fixed asset recognized	2410	5520	Revaluation reserve (equity)
Deferred tax liability accrued on the revaluation amount	5520	4310	DTL reduces the revaluation reserve

As a result:

• The revaluation amount in equity is shown net of deferred tax.
• In the future, as depreciation is charged or the asset is disposed of, the DTL will be gradually written off (reversed) through account 7710 (CIT expenses).
  

Depreciation Temporary Difference
In addition to the difference from the revaluation itself, an annual temporary difference arises due to the different amounts of depreciation in accounting and tax accounting. This also generates movement in the DTL accounts (reduction):

Transaction Description	Debit	Credit
Reduction of DTL as depreciation is charged in accounting	4310	7710

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5. Property Tax: Revaluation Has a Direct Impact
Unlike CIT, revaluation has a direct and immediate impact on property tax. As of 2026, this impact has become mandatory.

How Property Tax Is Calculated
The tax base is the average annual carrying value determined according to accounting data, taking into account revaluation.

This means:

1. You performed a revaluation (revaluation upward) of a building.
2. Its carrying amount in accounting increased.
3. The average annual value for calculating property tax automatically increases.
4. The amount of property tax payable increases.
   
   

Important: if revaluation has not been carried out for more than three years, the tax authority has the right to recalculate the tax based on market value.

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6. Typical Mistakes and How to Avoid Them
Mistake 1: Accounting for revaluation in tax depreciation
Companies erroneously continue to calculate tax depreciation from the revalued cost, attempting to increase CIT deductions.
How to avoid: Clearly separate accounting and tax accounting. In tax registers, always use the value balance of groups without taking revaluation into account.

Mistake 2: Ignoring deferred taxes
Accountants forget to accrue DTL on the revaluation amount, which distorts the financial statements and the company's equity.
How to avoid: When performing revaluation, immediately calculate the tax effect and make the entry: Debit 5520 Credit 4310.

Mistake 3: Confusion with property tax
Some companies continue to pay property tax based on the old (non-revalued) cost, believing that revaluation is "only for IFRS."
How to avoid: Starting from 2026, strictly comply with the requirement of Article 591 of the Tax Code of the Republic of Kazakhstan. When calculating property tax, take the carrying value taking into account revaluation.

Mistake 4: Missing the three-year deadline
Companies do not plan revaluation and miss the legally established three-year interval.
How to avoid: Include a clause on property revaluation in the inventory schedule at least once every 3 years. The countdown began in 2026.

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7. Practical Example: End-to-End Calculation
Initial Data:

• LLC "Alpha" on the General Tax Regime (GTR), VAT payer.
• Building purchased in 2020 for 100 million tenge.
• Useful life — 20 years.
• Accounting and tax depreciation (conditionally the same before revaluation): 5 million tenge per year.
• As of January 1, 2026, carrying amount: 70 million tenge (100 - 5 × 6 years).
• In 2026, mandatory revaluation was performed to a market value of 120 million tenge.
• Remaining useful life: 14 years.
• CIT rate: 20%.
• Property tax rate: 1.5% (conditional).
  

Step 1. Accounting for Revaluation

• Revaluation amount: 120 - 70 = 50 million tenge.
• Entry: Debit 2410 Credit 5520 — 50 million tenge.
  

Step 2. Calculation of Deferred Tax Liability (DTL)

• DTL = 50 million × 20% = 10 million tenge.
• Entry: Debit 5520 Credit 4310 — 10 million tenge.
• Net revaluation amount in equity: 40 million tenge.
  

Step 3. Depreciation After Revaluation (Accounting)

• New annual depreciation: 120 million / 14 = 8.57 million tenge.
  

Step 4. Tax Depreciation

• Tax cost (value balance of the group) remains 70 million tenge.
• Tax depreciation (assume 4% for buildings): 70 × 4% = 2.8 million tenge.
  

Step 5. Annual Temporary Difference for Depreciation

• Difference: 8.57 - 2.8 = 5.77 million tenge.
• This amount will reduce the DTL annually:
  
  • 5.77 × 20% = 1.154 million tenge.
  • Entry: Debit 4310 Credit 7710 — 1.154 million tenge (annually).
    

Step 6. Property Tax

• Carrying amount as of January 1, 2026: 120 million tenge (after revaluation).
• Property tax for 2026: 120 × 1.5% = 1.8 million tenge.
  (For simplicity, calculated from the value at the beginning of the year, although according to the rules, the average annual value is used.)
  

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Summary: Main Rules

1. From 2026, revaluation of property for property tax purposes is mandatory at least once every 3 years.
2. In accounting, after revaluation, depreciation increases (calculated from the new value).
3. In tax accounting (for CIT), revaluation results are not recognized — tax depreciation and deductions remain at the previous level.
4. The difference between the carrying amount and the tax value creates a taxable temporary difference and requires the accrual of a deferred tax liability (DTL).
5. DTL is accrued against equity (revaluation reserve), not against expenses.
6. From 2026, property tax is paid on the revalued amount.
   
   

Compliance with these rules will allow you to avoid tax risks, correctly prepare financial statements, and optimize the tax burden in the long term.

Annual reconciliation of actual asset availability with accounting data is not just a checkbox in the accounting department's work plan, but a key element of a business's financial security. In 2026, the procedure for inventory of fixed assets (FA) and inventories (INV) in Kazakhstan is taking on new nuances: digitalization of accounting, tightening of tax administration, and fresh clarifications from the Ministry of Finance require special attention from companies.
Why Inventory in 2026 Is Not Only an Obligation But Also an Opportunity
In addition to the direct obligation set out in Order of the Ministry of Finance of the Republic of Kazakhstan No. 241, a properly conducted inventory allows you to:

• Identify illiquid and damaged inventory – to write them off or sell them at a discount in a timely manner, rather than waiting for them to become dead stock.
• Detect hidden theft – statistics show that about 15% of shortages are detected precisely during the annual inventory, rather than during operations.
• Optimize taxes – correct documentation of losses allows them to be deducted for CIT and avoids VAT claims.
• Prepare for an audit or tax inspection – having a complete package of inventory documents reduces the risk of additional assessments.
  

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Regulatory Compass: What Has Changed in 2025–2026
The main document for commercial structures remains the same – the Accounting Rules (Order No. 241). However, it is important to consider:

• For state institutions, new Rules (Order No. 169) have been in effect since 2025. If your organization interacts with the public sector (rental of state property, execution of government orders), when conducting inventory of such property, you should be guided by the customer's requirements, which may differ from the general ones.
• Tax aspects – in 2026, tax authorities are especially carefully scrutinizing the validity of write-offs of inventories and fixed assets. Any shortage must be confirmed either by natural loss norms (approved industry standards) or by documents proving the absence of guilty parties (a ruling to terminate a criminal case, a court decision). Otherwise, additional CIT and VAT assessments will follow.
• Digitalization – the Ministry of Finance of the Republic of Kazakhstan recommends using electronic inventory lists and barcode scanners to improve accuracy and speed of verification. This is not an obligation, but a best practice.
  

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Deadlines: When to Start to Be on Time
Inventory must be conducted at least once a year. However, the specific date (for example, November 1 or December 1) is chosen by the company independently and recorded in its accounting policy. The main thing is to complete it before the annual financial statements are signed.

Advice: start the inventory in October-November, especially if you have a large range of inventory or geographically distributed warehouses. This will allow you to calmly, without rushing, process the results and make adjustments before the end of the year.
If inventory is conducted after December 31 (which is permitted if provided for in the accounting policy), all transactions from January 1 to the date of the inventory must be accounted for separately to avoid mixing new year balances with reporting period data.

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Who Is on the Commission: Requirements and Pitfalls
The composition of the commission is approved by order of the head. It must include:

• Chairman (usually a deputy director or chief accountant).
• Commission members – accountant, property accounting specialist, security service representative (optional).
• The financially responsible person (FRP) is present during the inspection but is not a member of the commission. This is important: if the FRP signs the inventory list as a commission member, they may subsequently challenge the results on the grounds that they were checking themselves.
  

Nuance: if the FRP is temporarily absent (illness, vacation), inventory on their site cannot be conducted. You must either wait for their return or appoint a responsible person during their absence and conduct an unscheduled inventory upon the transfer of affairs.

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Step-by-Step Procedure: From Receipt to Protocol
Step 1. Preparation and Receipts
FRPs submit the latest primary documents to the accounting department and give a receipt stating that all assets have been recorded or written off. The receipt is an important legal document: it confirms that at the start of the inventory, the records were complete.

Step 2. Technical Inspection
The commission checks the serviceability of scales, measuring containers, and seals the entrances to warehouses (if the inventory lasts several days). During the inventory, receipt and dispatch of inventory are suspended.

Step 3. Physical Count
Commission members, in the presence of the FRP, count, weigh, and measure inventory, and inspect fixed assets. Data is entered into inventory lists (recommended forms INV-1, INV-3). Important: inventory lists are filled out immediately, without drafts, in ink or ballpoint pen. Corrections are permitted only with an explanation and signatures of all commission members and the FRP.

Digital advice: use data collection terminals or tablets with online synchronization. This eliminates double entry and data transfer errors.

Step 4. Comparison with Accounting Data
The accountant enters the actual balances into the program and generates a comparison sheet. Here it is important to check for misgrading – when one item shows a surplus and another shows a shortage. Misgrading is only possible for homogeneous goods and for the same period, and the FRP must provide explanations.

Step 5. Analysis of Discrepancies
The commission reviews each discrepancy. If there is a shortage, the causes are determined: theft, natural loss, accounting error. If there is a surplus, the reasons for its occurrence are identified (for example, a receipt was not recorded). Based on the results, a protocol is drawn up with proposals for resolution. The protocol is approved by the head.

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How to Reflect Results in Accounting: 2026 Entries

Situation	Entry	Explanation
Surplus of FA/INV recorded	Debit 1310, 2410 – Credit 6280	Surplus is included in income at market value as of the inventory date
Shortage within natural loss norms	Debit 7010, 7210 – Credit 1310, 2410	Written off as expenses (cost of goods sold)
Shortage exceeding norms (guilty party identified)	Debit 1250 – Credit 1310, 2410	Shortage amount is charged to the guilty party (for subsequent deduction)
Shortage exceeding norms (guilty party not found or force majeure)	Debit 7470 – Credit 1310, 2410	Written off as other losses
Disposal of FA due to shortage	Debit 7410 – Credit 2410 (write-off of carrying amount) + write-off of accumulated depreciation	Additionally reflects the disposal of the fixed asset

Important: when writing off FA and INV, it is necessary to reverse VAT previously claimed as a credit if the further use of these assets is not related to taxable activities. Exception – documented force majeure (emergency situations).

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Tax Consequences: How Not to Overpay and Not to Receive a Fine

• CIT: Surpluses are included in total annual income (taxable). Shortages can be deducted only within the limits of natural loss norms approved by authorized bodies (for example, for food products, fuels and lubricants). Excess shortages are deductible only if there are documents confirming the absence of guilty parties. Without them, this is a non-deductible expense.
• VAT: when writing off INV (except in cases where assets are destroyed as a result of force majeure), VAT must be reversed. In the VAT declaration, this is reflected as an adjustment to the credit.
• Fines for lack of inventory: there is no direct fine for failure to conduct inventory, but tax authorities may consider the financial statements unreliable, which may result in administrative liability for officials (Article 238 of the Code of Administrative Offenses of the Republic of Kazakhstan – from 15 to 30 MCI).
  

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Special Situations: When General Rules Do Not Apply
Leased property
Leased FA and goods accepted for safekeeping are also subject to inventory. Separate inventory lists are prepared for them, and copies are sent to the lessor/bailor. If a shortage of leased property is identified, the company is obliged to compensate the owner for the losses.

Tolling raw materials
Raw materials received from a customer for processing are inventoried separately. The results are reported to the customer for reconciliation.

Change of financially responsible person (FRP)
Upon dismissal or transfer of an FRP, an unscheduled inventory must be conducted on their site. This protects both the employee and the company.

Force majeure (fire, theft)
If property is destroyed or stolen, inventory is conducted immediately after the incident. For tax write-off of such losses, acts from authorized bodies (fire service, police) will be required.

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Digital Inventory: 2026 Trend

More and more Kazakhstani companies are transitioning to automated inventory using:

• Barcode scanners and RFID tags – speeds up counting by 5–10 times, eliminates the "human factor."
• Mobile accounting applications – data goes directly into 1C or ERP, inventory lists are generated automatically.
• Drones and UAVs – for large warehouse complexes and open areas (accounting for coal, construction materials).
  
  

Automation does not eliminate legal requirements (signatures, receipts), but makes the process more transparent and faster.

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Checklist: Are You Ready for the Annual Inventory

1. An order has been issued on the composition of the commission and the deadlines.
2. Receipts on document submission have been obtained from FRPs.
3. Weighing/measuring equipment has been checked.
4. Inventory list forms have been prepared (or data collection terminals have been configured).
5. The procedure for handling misgrading has been determined.
6. A person responsible for reconciliation with accounting data has been appointed.
7. The procedure for VAT reversal upon write-off has been considered.
8. Deadlines for approving the protocol and reflecting the results have been established.
   

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Conclusion
Inventory 2026 is not an outdated ritual, but a modern management tool. In the era of digitalization and enhanced tax control, a properly organized asset check helps not only to avoid fines but also to optimize resources, identify reserves, and protect the business from losses. Give this process the attention it deserves – and the annual report will become not a headache, but a reflection of the real picture of your enterprise.