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

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    Question

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

    Answer

    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.

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    Question

    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.

    Answer

    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,...

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    Question

    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.

    Answer

    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...

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