Questions and answers from the meeting with the residents of Shymkent on July 8, 2026.

1

If a LLP has submitted an explanation to the notification on the results of camera control, is this considered as fulfillment of the said notification?

In accordance with paragraph 4 of Article 137 of the Tax Code, fulfillment of a notification on the results of camera control is recognized as:

1. in case of the taxpayer's agreement with the discrepancies specified in the notification – elimination of the revealed violations;

2. in case of disagreement with the discrepancies specified in the notification – submission of explanations and supporting documents regarding such discrepancies.

In this regard, the submission by the LLP of explanations on the notification regarding the identified discrepancies based on the results of camera control within the established timeframe is considered as fulfillment of the said notification.

2

I plan to rent out an apartment. Can I carry out such an activity as a self-employed person?

Yes, you can. Starting from 2026, individuals who rent out a residential house or an apartment are entitled to apply the self-employment tax regime. Registration as an individual entrepreneur is not required.

3

Are there any liability measures applied to taxpayers in the event of technical failures?

Regarding technical problems for which there is an Error Log (Protocol) drawn up together with the developers of information systems, and where the system's fault is indeed present, the liability of the taxpayer is completely excluded.

4

After the release of goods, the customs authority conducted an audit and revealed violations. Is the customs representative subject to liability?

A customs representative bears liability in accordance with the Code of the Republic of Kazakhstan "On Administrative Offenses" for inaccurate customs declaration of goods (for example, inaccurate information about goods, the chosen customs procedure, customs value, or country of origin of goods, or declaration of other inaccurate information that provides grounds for exemption from customs payments, taxes, or underpayment of customs payments, taxes, special, anti-dumping, countervailing duties, or leads to non-fulfillment or improper fulfillment of the obligation to pay them) committed through their fault, provided that this action does not contain signs of a criminally punishable offense.

At the same time, the customs representative is not held liable in cases provided for by paragraph 3 of Article 150 of the Code of the Republic of Kazakhstan "On Customs Regulation in the RK" (hereinafter – the CR Code of the RK), and when violations are committed through the fault of the declarant (for example, the declarant submitted invalid documents, including forged ones and/or those containing deliberately false (untrue) information).

Additionally, in the event of customs operations being performed by a customs representative on behalf of the declarant, the customs representative bears joint and several liability with such declarant for the payment of customs duties, taxes, special, anti-dumping, countervailing duties, except for cases provided for by subparagraphs 1)-7) of paragraph 5 of Article 494 of the CR Code of the RK.

5

On what grounds does the tax authority now appoint a tax audit?

Starting from January 1, 2026, the division of tax audits into planned and unplanned has been abolished. Now, a single concept is applied – tax audit, and its appointment is carried out only on the grounds provided for by the Tax Code.

The main ground is the decision of the tax authority, made based on the results of the analysis of tax risks, information received from taxpayers and state bodies, materials of camera control, results of other forms of tax control, or in the presence of other grounds directly provided for by the Tax Code. At the same time, public audit plans are no longer generated and published.

6

Can the tax authority appoint a tax audit without prior notification or without conducting a camera control?

Yes, it can. The new Tax Code does not establish an obligatory camera control before each tax audit.

If there are grounds provided by law for appointing an audit (for example, the results of tax risk analysis, materials from law enforcement agencies, or other grounds provided for by the Tax Code), the tax authority is entitled to issue an order to conduct a tax audit without prior delivery of a notification based on the results of camera control.

At the same time, it is worth noting that the statistics of completed tax audits show that more than 60% of comprehensive tax audits are initiated by the taxpayers themselves (tax applications for the refund of CIT, VAT, or for termination of business activity, etc.).

7

Is a tax audit mandatory during the reorganization of a legal entity?

Yes. Starting from January 1, 2026, the procedure has changed. Previously, if the reorganization (merger, accession, division, separation) itself was not a ground for a tax audit, the new Tax Code provides that the fulfillment of tax obligations during reorganization is carried out through tax administration.

At the same time, reorganization is allowed only after the completion of the respective tax administration activities:

under the simplified procedure – by conducting camera control;

in other cases – by conducting a tax audit.

Thus, a tax audit has become an integral part of the reorganization procedure in cases where the taxpayer does not fall under the simplified procedure of termination of activity or reorganization. The purpose of these changes is to eliminate the use of reorganization to evade tax obligations and obtain unjustified tax benefits, including VAT.

8

What is the percentage of adjustment applied to the amount of value-added tax (VAT) offset for agricultural products, aquaculture products, or commercial fishing products used for the purposes of taxable turnover at a zero rate?

According to paragraph 5 of Article 484 of the Tax Code, the adjustment of the offset VAT amount is performed by the exporter by reducing 80 percent of the offset VAT amount.

Additionally, we inform you that at the meeting of the Project Office for the introduction of the new Tax Code on June 18, 2026, a decision was made to initiate amendments to the Tax Code providing for the exclusion of this norm.

9

I work under the simplified tax regime and have 2 employees. Do I need to submit Tax Return Form (FNO) 200?

Yes. Starting from 2026, taxpayers applying the Special Tax Regime (STR) based on a simplified declaration must quarterly declare their employees in FNO 200.

At the same time, we are currently developing a service directly in the Taxpayer's Cabinet, where it will be sufficient to specify only the employee's IIN and calculated salary; the service will automatically calculate taxes and social contributions from the employee's salary. All that remains is to click the payment button.

When using this service, FNO 200.00 will not need to be submitted.

10

What actions do tax authorities take after receiving information from banking organizations?

Actions of the tax authority after receiving information:

After receiving information from second-tier banks, the state revenue bodies carry out measures in two stages:

First stage – informing the taxpayer;

Second stage – control measures.

I. Informing the taxpayer consists in sending an informative message to the "Taxpayer's Cabinet" about an individual receiving funds on a bank account not intended for entrepreneurial activities from 100 or more different individuals during each of three consecutive calendar months, with the total amount of receipts for the specified period exceeding 12 times the minimum wage (MW).

If the person is not registered as an individual entrepreneur or is an individual applying the special tax regime for the self-employed, the received income must be declared in the "Declaration of Income and Property" (FNO 270.00) for 2026 within the period from January 1 to September 15, 2027, and the individual income tax must be paid before September 25, 2027.

If the person is an individual entrepreneur, the received income must be declared in the following tax reports:

- for those applying the generally established regime: in the "Declaration of Individual Income Tax on Entrepreneurial Activity" (FNO 220.00) for 2026 from January 1 to March 31, 2027, with payment of individual income tax before April 10, 2027;

- for those applying the special tax regime based on a simplified declaration: in the "Declaration for Taxpayers Applying the Special Tax Regime based on a Simplified Declaration" (FNO 910.00) for the first half of 2026 from July 1 to August 15, 2026, with payment of individual income tax before August 25, 2026.

Informing the taxpayer does not require a response.

II. Control measures include the conducting of camera control by tax authorities based on the study and analysis of submitted tax reporting forms.

Based on the results of camera control, in case of discrepancies, a notification of discrepancies identified by the results of camera control is sent to the taxpayer in accordance with Article 137 of the Tax Code of the Republic of Kazakhstan.

The notification must be executed by the taxpayer within 30 working days from the day following the day of its delivery.

Execution of the notification is recognized as:

submission of tax reporting – in case of agreement with the identified discrepancies;

submission of explanations – in case of disagreement with the identified discrepancies.

Thus, camera control notifications are sent only if discrepancies are identified in the declarations submitted within the above-mentioned timeframes in accordance with the Tax Code.

11

Can a low extraction coefficient be a ground for an audit?

A low extraction coefficient itself is not an absolute ground for appointing an audit or refusing a VAT refund.

However, it is one of the risk indicators used by the risk management system when applying measures to minimize tax risk in relation to business entities.

It is worth noting that since January 1 of this year, provisions of the Tax Code have entered into force, providing for the mandatory application of this indicator when appointing audits. In particular, comprehensive audits are not appointed for tax periods in which the taxpayer's extraction coefficient is at least 90 percent of its upper indicator.

12

I provide taxi services and plan to additionally engage in hairdressing services. Can I register in the self-employment regime, carrying out two types of activities?

Yes, you can. The activities you perform are included in the list of activities permitted for individuals applying the self-employment regime.

13

I am registered as an individual entrepreneur and apply the special tax regime based on a simplified declaration. What deductions can I apply?

If your income for a calendar year exceeds 24,000 MRP (103,800,000 tenge in 2026), you are entitled to claim expenses on the payroll fund as deductions.

14

Am I subject to the "luxury" tax if several apartments or houses are registered under my name?

In the event that, according to the information provided by the NJSC "State Corporation 'Government for Citizens'" for 2026 (introduced since 2026), the cumulative value of objects of individuals subject to property tax exceeds the threshold limit of 450 million tenge, then in 2027 such individual will be presented with a property tax obligation for 2026 in an increased amount (2,946,600 + 2% of the amount exceeding 450.0 million tenge). This obligation is presented regardless of the number of objects.

15

Can exit from the country be restricted if there is an outstanding tax debt?

This provision entered into force on July 1, 2026. The restriction on leaving the Republic of Kazakhstan is applied if the tax debt, in an amount exceeding the threshold limit, has not been settled for more than three months.

16

Is VAT subject to adjustment upon writing off inventory?

If inventory is written off due to its spoilage, loss, or use for purposes not related to taxable turnover, the VAT amount previously claimed as an offset is subject to adjustment.

If the write-off is carried out within the limits of natural loss norms or in other cases provided for by the Tax Code, VAT adjustment may not be performed.

At the same time, the reasons for writing off must be supported by appropriate documents.

Reference: Article 480 of the Tax Code of the Republic of Kazakhstan and provisions regulating the adjustment of VAT offset amounts.

17

In which tax period and under what conditions can VAT paid on the import of goods from the EAEU be claimed as an offset?

In accordance with subparagraph 2 of paragraph 2 of Article 481 of the Tax Code, value-added tax to be offset is taken into account in the tax period in which the date of payment to the budget falls, including by conducting offsets in the manner determined by Articles 122 and 123 of the Tax Code, but not earlier than the 20th day of the month following the tax period determined by paragraph 6 of Article 530 of the Tax Code, for which such tax is calculated – when importing goods from the territory of a EAEU member state.

Thus, in the case of importing goods from EAEU countries with payment of import VAT, the VAT to be offset is taken into account in the tax period of the budget payment date, but not earlier than the 20th day of the month following the tax period determined by paragraph 6 of Article 530 of the Tax Code for which the tax is calculated.

18

What objective criteria will the tax authority guide itself by to establish the fact of business splitting?

From January 1, 2026, amendments to the Tax Code came into force, aimed at preventing schemes related to the distortion of information on financial and economic activities, artificial business splitting, and obtaining unjustified tax benefits, as well as ensuring the principle of fair competition.

In this regard, Article 30 of the Tax Code "The Principle of Good Faith of the Taxpayer (Tax Agent)" has been supplemented with a provision prohibiting actions aimed at distorting information on the facts of financial and economic activities, or splitting a business in order to obtain a tax benefit (tax savings) and reduce tax payments.

19

If the financial situation does not allow for a lump-sum debt settlement, is it possible to obtain a deferral (installment plan) for the payment of taxes?

The new Tax Code provides that if the amount of tax debt does not exceed 1500 MRP (6 487 500 tenge), it is possible to obtain a deferral (installment plan) for tax payments without collateral and without a bank guarantee. In this case, all mandatory notifications of the tax authority must be executed.

20

Is the possibility of using artificial intelligence technologies in customs administration being considered?

In general, the Committee is conducting systematic work on introducing AI into both customs and tax administration service processes.

In the "Keden" information system, a digital assistant for selecting the Commodity Nomenclature of Foreign Economic Activity (hereinafter – TN VED) code has already been implemented.

This service allows the user to enter the name or description of a product, after which the system automatically performs an intelligent search and suggests the most suitable TN VED codes with corresponding descriptions.

The introduction of this functionality contributes to improving the quality of product classification, reducing the number of errors in customs declaration, and simplifying the process of determining the TN VED code for participants in foreign economic activity.

In addition, testing of the functionality for automated pre-filling of preliminary information based on the submitted documents using artificial intelligence technologies is being conducted. The implementation of this mechanism will reduce the processing time of information, minimize the impact of the human factor, and improve the quality of preparation of customs documents.

Furthermore, testing of a system for analyzing X-ray images of inspection and screening systems (IDK) using artificial intelligence technologies has begun. The system provides automated recognition of objects and goods on X-ray images, generating preliminary analysis results and assumptions about the contents of inspected cargo.

The implementation of this solution will significantly increase the speed of X-ray image processing, reduce the load on officials analyzing the images, and provide an additional level of analytical support in decision-making.

The use of AI in image analysis contributes to increasing the effectiveness of customs control, reducing the probability of missing potentially significant objects, and ensuring a more objective, transparent, and high-quality customs inspection.

21

My FNO 328.00 is not being processed/posted in the ISNA system for the 3-month period of 2026, what should I do?

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].

22

I requested a breakdown of the notifications of violations revealed by the results of camera control.

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

23

Why should a compliant taxpayer bear tax consequences for the actions of second and subsequent-tier suppliers?

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.

24

According to the new Tax Code, the valuation of property of legal entities must be conducted once every 3 years. At the same time, the State Revenue Department for Turkestan city sent a notification about property revaluation. Please clarify which position should be followed.

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.

25

Please clarify the procedure for applying VAT exemption when selling medicines included in the list approved by the Government of the Republic of Kazakhstan. Also confirm whether the VAT exemption applies to the turnover of such medicines at all stages of their distribution in accordance with subparagraph 28) of Article 474 and subparagraph 17) of paragraph 1 of Article 479 of the Tax Code of the Republic of Kazakhstan.

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.