ORDER OF THE MINISTER OF FINANCE OF THE REPUBLIC OF KAZAKHSTAN

of October 24, 2025 No. 627

About approval of Rules and terms of delivery to the taxpayer (tax agent) of the preparatory act of tax audit, representation of written objection to the preparatory act of tax audit, and also consideration of such objection

According to Item 2 of article 169 of the Tax Code of the Republic of Kazakhstan PRIKAZYVAYU:

1. Approve Rules and terms of delivery to the taxpayer (tax agent) of the preparatory act of tax audit, representation of written objection to the preparatory act of tax audit, and also consideration of such objection according to appendix 1 to this order.

2. Recognize invalid some orders of the Ministry of Finance of the Republic of Kazakhstan according to appendix 2 to this order.

3. To provide to committee of state revenues of the Ministry of Finance of the Republic of Kazakhstan in the procedure established by the legislation of the Republic of Kazakhstan:

1) state registration of this order in the Ministry of Justice of the Republic of Kazakhstan;

2) placement of this order on Internet resource of the Ministry of Finance of the Republic of Kazakhstan after its official publication;

3) within ten working days after state registration of this order in the Ministry of Justice of the Republic of Kazakhstan submission to Department of legal service of the Ministry of Finance of the Republic of Kazakhstan of data on execution of the actions provided by subitems 1) and 2) of this Item.

4. This order becomes effective since January 1, 2026 and is subject to official publication.

Appendix 1

to the Order of the Minister of Finance of the Republic of Kazakhstan of October 24, 2025 No. 627

Rules and terms of delivery to the taxpayer (tax agent) of the preparatory act of tax audit, representation of written objection to the preparatory act of tax audit, and also consideration of such objection

Chapter 1. General provisions

1. These rules and terms of delivery to the taxpayer (tax agent) of the preparatory act of tax audit, representation of written objection to the preparatory act of tax audit, and also consideration of such objection (further - Rules) are developed according to Item 2 of article 169 of the Tax Code of the Republic of Kazakhstan (further - the Tax code) and determine procedure and terms of delivery by bodies of state revenues to the taxpayer (tax agent) of the preparatory act of tax audit, representation of written objection to the preparatory act of tax audit, and also consideration of such objection.

2. Provisions of Rules extend to the tax audits leading to charge of the amounts of taxes and other obligatory payments in the budget and also social payments, to reduction of losses, except for thematic checks:

1) according to the subitem 20) Item 2 of article 156 of the Tax Code concerning confirmation of reliability of the amounts of excess of the value added tax including shown to return and which are carried out concerning the taxpayer on the basis, specified in Item 5 of article 156 of the Tax Code;

2) concerning the income tax return from the budget based on the tax statement of the nonresident in connection with application of provisions of the international treaty on avoidance of double taxation, and also in connection with the address of the nonresident about de novo review of such tax statement.

3. Within these rules the following concepts are used:

1) written objection - written disagreement with results of the preparatory act of tax audit;

2) body of state revenues - the state body which within the competence is performing ensuring receipts of taxes and payments in the budget, customs regulation in the Republic of Kazakhstan, powers according to the prevention, identification, suppression and disclosure of the administrative offenses carried by the legislation of the Republic of Kazakhstan to maintaining this body, and also which is carrying out other powers, stipulated by the legislation the Republic of Kazakhstan;

3) the tax agent - physical person, the individual entrepreneur, person who is engaged in private practice, the legal entity, structural division of the legal entity, the operator of Internet platform who are recognized cases and procedure which are established by the Tax code the tax agent;

4) the preparatory act of tax audit - the document on preliminary results of tax audit constituted checking according to the tax legislation of the Republic of Kazakhstan and handed to the taxpayer (tax agent) before creation of the act of tax audit;

5) the taxpayer - person, structural division of the legal entity, being taxpayers and other obligatory payments in the budget.

Chapter 2. Procedure and terms of delivery to the taxpayer (tax agent) of the preparatory act of tax audit

4. Before creation of the act of tax audit, stipulated in Article 170 Tax codes, the official of body of state revenues hands to the taxpayer (tax agent) under list the preparatory act of tax audit.

5. The term of delivery of the preparatory act of tax audit is determined by the body of state revenues performing tax audit according to requirements, stipulated in Clause 163 Tax codes taking into account terms, stipulated in Clause 65 Tax codes and terms of preparation by the taxpayer (tax agent) of written objection for the preparatory act of tax audit, consideration of such objection and the prolongation provided by these rules.

Along with the preparatory act of tax audit the notice on suspension of term of conducting tax audit according to Item 6 of article 163 of the Tax Code, except for the case specified in Item 6 of these rules is handed.

6. In case of impossibility of delivery to the taxpayer (tax agent) of the preparatory act of tax audit due to the lack of it in the location specified in registration data of the taxpayer (tax agent) the body of state revenues according to the subitem 1) of Item 2 of article 181 of the Tax Code conducts tax examination with creation of the act of tax inspection.

Chapter 3. Procedure and terms of representation of written objection to the preparatory act of tax audit

7. The written objection to the preparatory act of tax audit is represented the taxpayer (tax agent) in the body of state revenues performing tax audit within 15 (fifteen) working days from the date of, the delivery of the preparatory act following behind day.

The taxpayer (tax agent) the written objection is represented by the following methods:

1) in attendance procedure.

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