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

of October 31, 2025 No. 659

About approval of Rules and the bases of decision making by body of state revenues about conducting tax audit, and also Rules of removal by body of state revenues of the decision on carrying out time inspection in the location specified in registration data of the taxpayer and (or) in the location of the taxation object and (or) object connected with the taxation

According to the subitem 3) Item 1 of Article 153 and Item 3 of article 158 of the Tax Code of the Republic of Kazakhstan PRIKAZYVAYU:

1. Approve:

1) Rules and the basis of decision making by body of state revenues about conducting tax audit according to appendix 1 to this order;

2) Rules of removal by body of state revenues of the decision on carrying out time inspection in the location specified in registration data of the taxpayer and (or) in the location of the taxation object and (or) object connected with the taxation according to appendix 2 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 provision in 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 on 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. 659

Rules and the basis of decision making by body of state revenues about conducting tax audit

Chapter 1. General provisions

1. These rules and the basis of decision making by body of state revenues about conducting tax audit (further – Rules) are developed according to the subitem 3) of Item 1 of article 153 of the Tax Code of the Republic of Kazakhstan (further – the Tax code) and determine procedure and the basis of decision making of body of state revenues about conducting tax audit.

2. The decision of body of state revenues on conducting tax audit is passed by bodies of state revenues within the established powers the tax legislation of the Republic of Kazakhstan:

Committee of state revenues of the Ministry of Finance of the Republic of Kazakhstan (further – Committee);

departments of state revenues of Committee on areas, the cities of republican value and the capital (further – Department);

managements of state revenues of Department on areas, the cities and areas in the cities (further – Management).

3. In these rules the following concepts are used:

1) territorial subdivisions on areas, the cities and areas in the cities, and also interdistrict territorial subdivisions – district and city levels of the state authorized bodies;

2) APPK – Administrative procedural Procedure Code of the Republic of Kazakhstan;

3) bodies of state revenues – Committee, Department, Management;

4) territorial subdivisions on areas, the cities of republican value and the capital – regional levels of the state authorized bodies.

Chapter 2. The decision making basis about conducting tax audit by Committee of state revenues of the Ministry of Finance of the Republic of Kazakhstan

4. Decision making about conducting tax audit is performed by committee in case of identification (establishment) of violations of tax and other legislation of the Republic of Kazakhstan on the following bases and questions:

1) addresses of taxpayers and information of the central state bodies of the Republic of Kazakhstan;

2) for earlier checked period, the statements which except for arrived, requirements, claims of the taxpayer (tax agent) and resolutions provided by the Code of penal procedure of the Republic of Kazakhstan;

3) non-execution of the motivated decision on monitoring of large taxpayers;

4) disagreement with the motivated decision on horizontal monitoring concerning execution of the tax liability and (or) non-execution of such decision;

5) non-compliance with requirements of the legislation of the Republic of Kazakhstan on state regulation of production and turnover of separate types of excise goods, and also turnover of aviation fuel, biofuel, fuel oil;

6) transfer pricing, the provided Law of the Republic of Kazakhstan "About transfer pricing";

7) minimization of tax risks according to Item 2 of article 93 of the Tax Code;

8) legitimacy of application of provisions of international treaties.

Chapter 3. The decision making basis about conducting tax audit by departments of state revenues of Committee of state revenues of the Ministry of Finance of the Republic of Kazakhstan

5. Decision making about conducting tax audit is performed by department in case of identification (establishment) of violations of tax and other legislation of the Republic of Kazakhstan on the following bases and questions:

1) addresses of taxpayers and information regional and equated to them (to the cities of republican value) state bodies of the Republic of Kazakhstan;

2) determination of the tax liability on settlement with the taxpayer (taxpayers) concerning whom, (which) pre-judicial investigation upon making of actions according to the statement of the invoice without the actual performance of works, rendering services, shipment of goods is made;

3) determination of the tax liability on settlement with the taxpayer (taxpayers) concerning whom, (which) the body of state revenues applies suspension of the statement of electronic invoices according to the subitem 1) of Item 1 of article 88 of the Tax Code;

4) confirmation of the actual making of turnover on sales of goods, performance of works and rendering services;

5) confirmation of availability of the violations specified in the difference notice, revealed by results of cameral control;

6) receipt of data on expenditure of money and (or) other property from foreign states, the international and foreign organizations, foreigners, stateless persons, in some cases.

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