Imagine this: you've been successfully running your business, paying taxes, and now you've decided to close the company. It would seem like a routine matter—submit an application, receive a certificate, and forget about it. But that's not the case. Especially if your partnership was registered for value-added tax. Amendments came into force in Kazakhstan on January 1, 2026, completely revamping the VAT deregistration procedure.
Previously, entrepreneurs could voluntarily deregister from VAT, citing low turnover. Now this loophole has been firmly closed. The only legal way for a VAT payer under the general regime to cease their VAT status is to either liquidate the company or switch to a special tax regime. If you choose the former, you need to clearly understand the procedure to avoid fines and being stuck in liquidation for months.
1. The place of the procedure in the general liquidation processTo avoid confusion about the sequence, imagine liquidation as a ladder, with each rung leading to the next. Deregistration from VAT is not a separate island, but part of a larger journey.
The correct order of steps is:- A decision was made to liquidate and a committee was appointed.
- An announcement was published in the media, and the two-month waiting period for creditors has passed.
- An inventory was carried out, an interim liquidation balance was drawn up and approved.
- Here and now - submitting documents for deregistration from VAT.
- Conducting a tax audit.
- Settlements with creditors.
- Drawing up the final balance sheet and closing the company.
Key point: submitting a VAT exemption application occurs
after the interim balance has been approved, but before you begin paying off your debts to creditors. Why? Because it's at this stage that the tax authorities must verify your obligations to the budget and approve further actions.
2. What documents and where to bring themStarting in 2026, the required documentation became more stringent, and the deadlines became more stringent. The legislator clearly decided that parting with the budget should be as thorough as its introduction.
VAT Liquidation Declaration (Form 300.00)
This isn't a regular quarterly report. It's a special document where you draw a line under your entire tax history. The declaration must be marked "
liquidation."
What is included in the declaration:
- All taxable turnover for the last reporting period (from the date of the previous declaration to the day preceding the filing of the liquidation declaration).
- A separate column is for inventory balances. This may come as a surprise to many: if you have goods, materials, or fixed assets in your warehouse or balance sheet for which you previously claimed VAT as a credit, you'll now have to reclaim that tax. The rate is 12% of the inventory value. The amount accrues and is payable to the budget.
- Accounts receivable (if any) - no tax is charged on them, but they must be reflected.
The declaration is completed on the date preceding the filing date. This means you're essentially recording the state of your affairs at the time of your tax waiver.
Application for deregistration from VAT
The application form is standard, but there's a technical caveat: as of 2025-2026, electronic filing of such an application through the taxpayer account is blocked (at least for voluntary withdrawal). Therefore, the optimal route is an in-person visit to the State Revenue Service at your place of registration, or sending a representative with a notarized power of attorney.
What should be in the application:
- Full name of LLP, BIN.
- The reason for removal is “due to liquidation”.
- Date, signature of the liquidator (or chairman of the liquidation commission).
Submission deadlines are critical
You have only 3 working days from the date of approval of the interim liquidation balance sheet to:
- submit a liquidation declaration for VAT;
- submit an application for deregistration;
- and at the same time - an application for a liquidation tax audit.
If you miss the deadline, the tax office may refuse to accept the documents, forcing you to either reinstate the deadline through explanations or start the process over again. In practice, this can delay the liquidation process for weeks.
3. What happens to VAT after filing documentsTax audit
After receiving your documents, the tax authority is required to begin an audit. This deadline
is no later than 10 business days from the date of application submission. The audit can take up to 30 business days (depending on the scope).
What they check:- Correctness of VAT calculation for recent periods.
- Justification for the allocation of amounts to offset.
- Existence of debt.
- Correctness of VAT calculation on remaining goods.
If errors are discovered during the audit, they are reflected in the report, but—an important advantage—
no penalties or fines are assessed unless the errors are due to intentional understatement. This mitigation applies specifically to liquidation.
If there is an overpayment of VAT
It often happens that a company has paid VAT regularly, but an overpayment (debit balance) has accumulated in its personal account. Many hope that this money can be recovered during liquidation.
Unfortunately, this is not the case. Since 2026, a rule has been in effect: upon liquidation, the VAT amount that should be offset (i.e., the overpayment)
is not refunded. It is simply written off as state revenue. It's harsh, but it's the law.
Therefore, if you know you have an overpayment, try to use it before filing a liquidation tax return—for example, by offsetting it against other taxes (if legally possible). But be careful: such actions must be legal and not arouse suspicion.
If there is a VAT debt
The opposite situation occurs when you owe money to the budget. It's simple:
the debt must be repaid before submitting the documents. Penalties and fines are also paid. Otherwise, the tax office won't deregister you or issue a certificate of no outstanding debt, without which the liquidation process cannot be completed.
4. The main pitfalls and how to avoid themStone 1. VAT on remaining goods
Many accountants forget about this requirement or mistakenly assume that since the goods aren't sold, there's no tax. However, the tax office will definitely check during an audit: if the goods were purchased with VAT and that VAT was offset, then upon liquidation (when the goods aren't sold), the tax must be refunded.
What to do: Conduct an inventory in advance. Calculate the remaining balance. Make sure it's reflected correctly in the declaration. Then include this amount in your liquidation expenses.
Tip 2. Electronic filing is unavailable. Don't risk submitting your application through your account if the system doesn't accept it. It's better to spend your time visiting the tax office in person. Bring the following:
- passport;
- document confirming authority (decision on appointment as liquidator);
- a completed application in two copies;
- declaration on paper (or with an electronic medium).
You will receive an acceptance mark on site, and you will have proof of meeting the deadline.
Stone 3. Confusion in order
Remember: first, approve the interim balance sheet, then—within three days—submit the declaration and application. Not the other way around. If you submit the application before the balance sheet is approved, the tax authorities may return the documents, as the company's true financial position is still unclear.
Stone 4. Forgot about the remaining balances, but have already filed a declaration. If, after filing, you discover that you forgot to include some remaining balances in the declaration, you will have to file an additional (clarified) declaration. This is possible, but it will delay the audit and raise additional questions. It's best to double-check everything immediately.
5. After deregistration: what next?Once the tax authority has verified the tax return, ensured there are no outstanding debts, and possibly conducted a desk audit, it will decide whether to deregister for VAT purposes. The decision is made within
five business days of the audit's completion (but not before the audit is complete).
After this you will be given:
- notification of deregistration from VAT;
- certificate of absence of tax arrears (or reconciliation report).
These documents are needed for the next stage – settlements with creditors and drawing up the final liquidation balance sheet.
Important: Even after deregistration, the company continues to exist as a legal entity until it is removed from the register. However, you no longer calculate or pay VAT (except for any additional charges resulting from an audit).
6. Typical questions and answersQuestion: Is it possible to simply close the company without filing an application for VAT exemption?
Answer: No. Until you are deregistered for VAT purposes, the liquidation cannot be completed. A tax audit is mandatory, and deregistration occurs automatically during this process, but only upon your request.
Question: If I have no remaining goods and no debts, is the procedure simpler?
Answer: Yes, it's technically easier, but you still need to submit documents. And there will still be an audit (at least an office audit).
Question: I deregistered from VAT during liquidation, but then changed my mind about closing the company. Can I reinstate my VAT records?
Answer: Theoretically, yes, but this will require a new VAT registration if grounds (turnover) arise. You'll have to re-apply for VAT registration.
Question: Is it necessary to pay VAT when transferring property to participants after liquidation?
Answer: If the property is transferred to a participant as an individual, it is not subject to VAT (it is not considered a sale). However, if the participant is a legal entity, there may be some nuances. It is best to consult an accountant.
Summary:
Five Key Rules for Successful VAT Withdrawal During Liquidation
- Don't rush to submit your documents —wait until the interim liquidation balance is approved, but after that, complete the process within three days.
- Don't forget about the remaining inventory —take inventory and calculate VAT on goods, materials, and fixed assets for which tax was deducted.
- Don't count on a refund of overpayments —if you have a VAT debit balance, it will be lost. Use it before liquidation, if possible.
- Don't experiment with electronic submission —if the system is glitchy, go in person. It's more reliable.
- Don't leave debts behind - pay off all VAT arrears and penalties before filing.
Deregistration from VAT is one of the most crucial stages of liquidation. A mistake here can cost not only time but also money. If you're unsure, consider inviting a qualified accountant or lawyer for a consultation. It's cheaper than litigating with the tax authorities or redoing the entire process.