Department of state revenue for Shymkent

In accordance with Article 503 of the Tax Code, starting from January 1, 2026, the VAT rate is 16 percent. A reduced rate of 5 percent (from January 1, 2027 – 10 percent) applies to taxable turnover on the sale and import of medicines, medical devices, medical device components, and technical auxiliary (compensatory) means. The list of such goods is approved by Resolution of the Government of the Republic of Kazakhstan No. 1204 dated December 31, 2025. At the same time, according to subparagraph 28) of Article 474 and subparagraph 17) of paragraph 1 of Article 479 of the Tax Code, turnover on the sale and import of medicines intended for the treatment of orphan and socially significant diseases, as well as medical services (including those provided as part of a complex) within the guaranteed volume of free medical care and the system of compulsory social health insurance, are exempt from VAT. The list of medicines and medical services specified in subparagraph 28) of Article 474 and subparagraph 17) of paragraph 1 of Article 479 of the Tax Code, as well as the procedure for applying VAT exemption upon their import, are approved by Resolution of the Government of the Republic of Kazakhstan No. 1203 dated December 31, 2025. In turn, the VAT exemption applies at all stages of distribution of goods (import – wholesale trade – retail trade) to the final consumer, subject to the goods' conformity with the approved List and compliance with the requirements of the legislation regulating the application of this tax benefit, including the procedure for applying VAT exemption during import.

Yes, the new Tax Code provides for mandatory revaluation of real estate for the purpose of determining the tax base for property tax at least once every 3 years. Since this norm was introduced from 2026, the first mandatory revaluation must be conducted by the end of 2028. At the same time, for taxpayers who account for fixed assets using the fair value method, the obligation to account for the revalued value is already provided for in accounting. The tax base in the form of the average annual book value is determined precisely according to accounting data. This is not a new rule; it has always been in force. Accordingly, if fixed assets are accounted for using this method and a revaluation was made, it must be reflected in accounting, which will affect the tax base and, consequently, the amount of property tax.

According to the provisions of the new Tax Code, refusal of a VAT refund is possible exclusively if there are tax risks of the immediate suppliers, for whom the issuance of ESFs has been limited, who are involved in criminal cases under Articles 216 and 245 of the Criminal Code, and who have direct signs of reducing tax liabilities. At the same time, within the framework of control, it is necessary to check all risks established during the audit. Thus, according to paragraph 43 of the Rules for VAT Refund, the State Revenue Department generates a "Supplier Pyramid" report along the entire chain of the exporter's suppliers in order to identify suppliers for whom reductions in tax liabilities have been established as a result of tax evasion schemes, and for whom cross-audits must be conducted.

In 2024, for the period of 01.01.2020-31.12.2022, an unplanned tax audit was conducted at "Energoresurs" LLP on the basis of subparagraph 1 of paragraph 3 of Article 145 of the Tax Code of the RK (2017 edition). Based on the audit results, notification No. 75 dated April 8, 2024, was delivered, with an additional assessment of 366 529 619 tenge, including 159 492 457 tenge under KBK 101111 (interest/fine of 31 699 988 tenge) and 163 308 712 tenge under KBK 105101 (interest/fine of 12 034 461 tenge). The taxpayer appealed the notification to the Ministry of Finance of the RK, where a Decision fully in favor of the tax authorities was issued under No. ZT-2024-03672406 dated July 4, 2024. Further, the taxpayer filed a lawsuit in the Specialized Interdistrict Administrative Court of Turkestan Region. The decision of this court was issued on September 30, 2024, case No. 5194-24-00-4/778, in favor of the Tax Authority. After the court decision, the taxpayer filed an appeal with the Judicial Chamber for Administrative Cases of Turkestan Regional Court, where the appellate commission also left the decision of the first instance court unchanged. Exercising its rights, the taxpayer filed a cassation appeal to the Cassation Court for Administrative Cases of the Republic of Kazakhstan, which issued a decision on August 21, 2025 (6003-25-00-4k/1064) in favor of the tax authority. Currently, "Energoresurs" LLP is undergoing rehabilitation, recovery, and appealing the "Ruling on the initiation of a rehabilitation procedure case." The following camera control notifications have been generated and delivered to the taxpayer as of today: 1) 5815KI500046 dated 20.11.2025. Overstatement of deductions for CIT on acquired goods, works, and services, established on the basis of a comparison of FNO 100.00 data with information from received ESFs, acquired services from individuals under civil-law contracts (the subject of which is the provision of services or execution of works), data on services received from a non-resident, information on imports from EAEU countries (FNO 328.00), as well as cargo customs declaration (GTD) data on imports from third countries. Violation amount: 548 996 567 tenge. Period covered by camera control: 01.01.2022-31.12.2022. 2) 5815X4500001 dated 13.10.2025. During the camera control of the VAT declarations submitted by you and the electronic invoices received, an overstatement of the VAT amount claimed for offset was established (in violation of Chapter 46 of the Tax Code). Violation amount: 96 584 718 tenge. Period covered by camera control: 01.01.2022-30.06.2025. 3) 5815OO800006 dated 30.09.2025. During the camera control, it was established that in violation of Article 400 of the Code of the RK "On Taxes and Other Obligatory Payments to the Budget" (Tax Code), the amounts of offset VAT were overstated. Violation amount: 21 365 214 tenge. Period covered by camera control: 01.07.2022-30.09.2022. Regarding notifications No. 5815KI500046 and No. 5815OO800006, the identified violations were taken into account during the tax audit conducted in 2024, and therefore the appointment of a tax audit under these notifications is not considered. Under notification No. 5815X4500001, the violations were not fully taken into account during the tax audit. In addition, part of the period covered by this notification does not fall within the period of the specified audit. In this regard, the procedures provided for by the Administrative Procedural Code of the Republic of Kazakhstan will be carried out under this notification to schedule a tax audit.

An order has been given to send a breakdown for 3 notifications of violations identified based on the results of camera control.

The State Revenue Committee's information systems have undergone works regarding the acceptance and processing of tax reporting form 328.00. Posting and reversing (stornierung) of FNO 328.00 is carried out as normal. Also, the submission of FNO 328.00 to replace a previously submitted form is operating stably. If necessary, it is possible to submit FNO 328.00 in replacement of a previously submitted one. To identify specific technical problems, it is necessary to conduct a targeted check. For this, please provide current screenshots of the error to the SRC or contact the Support Service through the "Support – Feedback" section of the KNP ISNA portal. The response to your request will be sent to the email address specified in the user profile. In addition, the inquiry can be sent to the email of the KNP ISNA Support Service: [email protected].