ORDER OF THE MINISTER OF FINANCE OF THE REPUBLIC OF KAZAKHSTAN

of September 30, 2025 No. 548

About approval of Rules of purpose of counter tax audits

According to Item 2 of article 157 of the Tax Code of the Republic of Kazakhstan PRIKAZYVAYU:

1. Approve Rules of purpose of counter tax audits 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 the 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.

4. This order becomes effective on 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 September 30, 2025 No. 548

Rules of purpose of counter tax audits

Chapter 1. General provisions

1. These rules of purpose of counter tax audits (further - Rules) are developed according to Item 2 of article 157 of the Tax Code of the Republic of Kazakhstan (further - the Tax code) and determine procedure for purpose of counter tax audits.

2. The purpose of purpose of counter tax audits is receipt of the additional information at suppliers and (or) buyers about the performed operations between taxpayers, confirmations of their fact of implementation with use of data from the information system "Electronic Invoice", documents and data on activities of the taxpayer.

3. Counter tax audits are appointed by bodies of state revenues on the questions arising:

during complex or thematic tax audit, carrying out horizontal monitoring;

in case of receipt of requests from tax or law enforcement agencies of other states, the international organizations according to international treaties (agreements) on mutual cooperation between tax or law enforcement agencies, one of the parties of which is the Republic of Kazakhstan, and also under agreements, concluded by the Republic of Kazakhstan with the international organizations.

4. Counter tax audit covers the period within terms of limitation period, stipulated in Clause 65 Tax codes.

Chapter 2. Procedure for purpose of counter tax audits when conducting complex or thematic tax audit, horizontal monitoring

5. Before purpose of counter tax audit when conducting complex or thematic tax audit, horizontal monitoring concerning suppliers and buyers (further - partners) the checked taxpayer (tax agent), and also concerning persons performing transactions with participants of horizontal monitoring, to the official of body of state revenues performing tax audit or to the official of Committee of state revenues of the Ministry of Finance of the Republic of Kazakhstan, the performing horizontal monitoring with use of data from information system of electronic invoices, documents (including accounting) and data on activities of the taxpayer, it is required:

1) carrying out unloading and determination of the list of the main buyers and suppliers, on which established facts not of reflection of settlement in tax statements;

2) carrying out reconciliation of settlement between buyers and suppliers for determination of source of goods origin, works and services;

3) forming of requests for counter auxiliary checks concerning buyers and suppliers, on which established facts not of reflection of settlement in tax statements, lack of goods origin, application of restriction of the statement of the electronic invoice.

Completion date of request for counter tax audit when conducting complex or thematic tax audit, horizontal monitoring by bodies of state revenues does not exceed 20 (twenty) working days.

6. Requests for conducting counter tax audits are not created on settlement with the following suppliers (taxpayers):

1) performing delivery of electrical and (or) heat energy, water, gas, communication services (if listed is not goods);

2) subject to tax monitoring;

3) recognized idle according to the procedure, determined by article 91 of the Tax Code;

4) in the relation which pre-judicial investigation upon making of actions according to the statement of the electronic invoice without the actual performance of works, rendering services and shipment of goods is made;

5) registration (re-registration), and also the conclusion of the transaction which it is acknowledged invalid based on the judgment which took legal effect;

6) the nonresidents performing works (services), not being taxpayers on value added in the Republic of Kazakhstan and not performing activities through branch, representation.

The taxpayers specified in this Item of Rules are not subject to counter auxiliary check if other not stipulated in Item 7 these rules.

7. For purpose of counter auxiliary check or sending an inquiry in body of state revenues about conducting counter auxiliary check, and also counter check during horizontal monitoring bodies of state revenues, including consider the following cases:

1) not receipt of the goods (works, services) received according to transactions, proceeds from sales of goods (works, services), property;

2) purchase of goods (works, services) or shipment of goods, performance of works, rendering services in the documents processed with violation of the requirements established by the legislation of the Republic of Kazakhstan (including with the allowed corrections, erasures, indistinct, indistinct signatures, stamps, seals of the organizations, except for the legal entities belonging to subjects of private entrepreneurship), without the conclusion of agreements in writing;

3) impossibility of real implementation by the taxpayer of transactions (transaction) taking into account time, the locations of property or amount of the material resources economically necessary for delivery of goods, performance of works or rendering services;

4) lack of necessary conditions for achievement of results of the related economic activity owing to lack of manpower, fixed assets, production assets, storage facilities, vehicles;

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