I.O'S ORDER. MINISTER OF FINANCE OF THE REPUBLIC OF KAZAKHSTAN

of October 31, 2025 No. 654

About some questions of execution of the tax liability in case of liquidation, reorganization and the termination of activities by taxpayers (tax agents)

According to Item 6 of Article 74, Item 2 of article 113 of the Tax Code of the Republic of Kazakhstan (Tax code), PRIKAZYVAYU:

1. Approve:

1) Rules of execution by taxpayers (tax agents) of the tax liability in case of liquidation, including separate categories of taxpayers (tax agents), according to appendix 1 to this order;

2) Rules of execution by taxpayers (tax agents) of the tax liability by reorganization, including separate categories of taxpayers (tax agents) according to appendix 2 to this order;

3) Rules of execution of the tax liability in case of the termination of activities by taxpayers (tax agents), including separate categories of taxpayers (tax agents), according to appendix 3 to this order;

4) the Simplified procedure for execution of the tax liability in case of the activities termination, and also conditions of reference of taxpayers to separate categories of taxpayers, according to appendix 4 to this order;

5) form of the tax statement on conducting tax audit according to appendix 5 to this order;

6) form of the tax statement for the termination of activities according to appendix 6 to this order.

2. 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.

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

Appendix 1

to the Order i.o the Minister of Finance of the Republic of Kazakhstan of October 31, 2025 No. 654

Rules of execution by taxpayers (tax agents) of the tax liability in case of liquidation, including separate categories of taxpayers (tax agents)

Chapter 1. General provisions

1. These rules of execution by taxpayers (tax agents) of the tax liability in case of liquidation, including are developed by separate categories of taxpayers (tax agents) (further – Rules) according to Item 6 of article 74 of the Tax Code of the Republic of Kazakhstan (further – the Tax code) and determine procedure for execution by taxpayers (tax agents) for the tax liability in case of liquidation, including separate categories of taxpayers (tax agents).

2. Under the liquidated taxpayer (tax agent) (further – the liquidated person) within these rules the following persons are recognized:

the liquidated legal entity – the resident;

the structural division of the legal entity stopping activities in the Republic of Kazakhstan (further – structural division) – the nonresident;

the permanent organization of the legal entity stopping activities in the Republic of Kazakhstan – the nonresident;

the structural division of legal resident person stopping activities.

Chapter 2. Procedure for execution of the tax liability by the liquidated person

Paragraph 1. General provisions of execution of the tax liability by the liquidated person

3. Liquidating tax statements are constituted by the liquidated person on types of tax, payments in the budget and to social payments on which such person is payer and (or) the tax agent, from the beginning of tax period at which the tax application for conducting tax audit in form according to appendix 5 to this order is submitted (further – the tax statement on check), before date of submission of such statement.

If the term of submission of the next tax statements comes after submission of liquidating tax statements, submission of such next tax statements is made no later than date of submission of liquidating tax statements.

4. The liquidated person pays taxes, payments to the budget and social payments reflected in liquidating tax statements no later than 10 (ten) calendar days from the date of submission to body of state revenues (further – OGD) to liquidating tax statements.

If the due date for tax payment, payments in the budget and the social payments reflected in the tax statements provided before liquidating tax statements comes after the expiration specified in part one of this Item, payment (transfer) is made no later than 10 (ten) calendar days from the date of submission to OGD of liquidating tax statements.

5. The tax debt of the liquidated person arising including on the bases specified in items 4 and 10 these rules is settled by its money including received from realization of its property according to the procedure of priority according to Item 5 of article 183 of the Tax Code.

At the same time the tax debt of the liquidated person, in case of execution by such legal nonresident person of the tax liabilities in total on group of permanent organizations, structural divisions of legal entities through the permanent organization stopping activities, structural division is also repaid.

6. If the property of the liquidated legal entity is not enough for repayment in full tax debt, the remaining part of tax debt is repaid by founders (participants) of the liquidated person in cases, the provided procedure according to Item 5 of article 183 of the Tax Code.

7. If the liquidated person has excessively paid amounts of taxes, payments in the budget and penalty fee, then the specified amounts are subject to offsetting on account of repayment of tax debt of the liquidated person according to the procedure, determined by article 122 of the Tax Code.

If the liquidated person has mistakenly paid amounts of taxes, payments in the budget and penalty fee, the specified amounts are subject to offsetting according to the procedure, determined by article 123 of the Tax Code.

8. If the liquidated person before date of removal from registration accounting of the taxpayer on value added has the excess amount on the value added tax referred in offsetting over the amount of the accrued tax which is subject to return, the specified excess is subject to return according to the procedure, determined by article 125 of the Tax Code.

9. In case of absence at the liquidated person of tax debt:

1) mistakenly paid amounts of taxes, payments in the budget and penalty fee are subject to return to this liquidated person according to the procedure, determined by article 123 of the Tax Code;

2) excessively paid amounts of taxes, payments in the budget and penalty fee are subject to return to this liquidated person according to the procedure, determined by article 122 of the Tax Code;

3) paid amounts of penalties are subject to return to this liquidated person on the bases and according to the procedure which are stipulated in Clause 122 Tax codes;

4) the amounts of customs duties, taxes, customs fees and the penalty fee levied by customs authorities which are excessively (mistakenly) paid to the budget are subject to return to this legal liquidated entity according to the procedure, determined by the customs legislation of the Republic of Kazakhstan.

10. In case, such obligations specifies representations by the liquidated person of tax statements on the arisen tax liabilities from date of submission of liquidating tax statements before date of completion of liquidating tax audit, OGD in appendix to the act of tax audit without charge of penalty fee and application of penalties according to Item 6 of article 170 of the Tax Code.

11. In case of the income of physical persons and nonresidents, taxable at payment source, in the form of dividends during the period from the date of following behind day of completion of liquidating tax audit about day of approval of the liquidation balance sheet the liquidated person represents to OGD in the place of the stay additional tax statements to liquidating tax statements on such tax liability and to perform it in full.

12. The liquidated legal entity within 3 (three) working days from the date of decision making about liquidation in writing reports about it in OGD in the place of the stay according to article 49 of the Tax Code.

13. The liquidated legal entity within 3 (three) working days from the date of approval of the interim liquidation balance sheet, represents according to article 49 of the Tax Code to body of state revenues in the location (further – OGD) at the same time:

1) the tax statement for conducting tax audit in form according to appendix 5 to this order (further – the tax statement on check);

2) liquidating tax statements.

14. Tax audit begins no later than 10 (ten) working days after receipt of OGD of the tax statement on check of the liquidated person.

Tax audit is carried out according to Chapter 15 of the Tax code.

15. The liquidated legal entity represents the liquidation balance sheet within 3 (three) working days from the date of completion of tax audit in case of simultaneous observance of the following conditions:

1) lack of tax debt, debt on social payments, including following the results of the performed tax administration;

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