Shymkent “03” June 2026
Pursuant to Order No. 223 dated 18 March 2026 of the Head of the State Revenue Department of Shymkent (hereinafter referred to as the “Department”) “On Conducting an Internal Analysis of Corruption Risks,” the Department conducted an internal analysis of corruption risks in organizational and managerial activities, as well as in regulatory legal acts affecting the activities of tax and customs administration divisions.
This analytical report has been prepared based on the identified corruption risks agreed upon with the relevant specialized divisions of the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan.
Period of analysis: 30.03.2026 – 10.06.2026.
Head of the Department – B. Karymsakov.
Head of the Working Group – Deputy Head of the Department E. Uzbekov.
Members of the Working Group:
U. Baktybayeva, E. Artykbay, T. Turganbayev, N. Amiraliyev, A. Tolen, A. Zeyev, N. Sergazin, Zh. Aryntayev, Zh. Beisenbayeva, T. Tlenshin, S. Nurkhan, A. Tazhenov, U. Akhmetov, D. Turekhanov, A. Seydegasiev, B. Omartayev.
No corruption risks related to human resources management were reviewed during the period of the internal corruption risk analysis in the Department’s activities.
No corruption risks related to the settlement of conflict of interest were reviewed during the period of the internal corruption risk analysis in the Department’s activities.
No corruption risks related to the provision of public services were reviewed during the period of the internal corruption risk analysis in the Department’s activities.
No corruption risks related to the implementation of permitting functions, agreed upon with the relevant specialized divisions of the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan, were reviewed during the period of the internal corruption risk analysis in the Department’s activities.
Description of the corruption risk:
In accordance with paragraph 2 of Decision No. 263 of the Customs Union Commission “On the Procedure for the Use of Transport (Shipping), Commercial and/or Other Documents as a Goods Declaration,” when customs declaring goods using transport (shipping), commercial and/or other documents as a goods declaration, the declarant or customs representative shall submit to the customs authority, together with such documents, a written application or a list of goods.
Furthermore, submission of a goods declaration is not accompanied by the submission of its electronic form to the customs authority.
Transport (shipping), commercial and/or other documents may be used as a goods declaration for Eurasian Economic Union goods where the customs value does not exceed EUR 200 and other legal conditions are met.
For submission in paper-based format, FEA participants physically visit the customs post and submit an application together with shipping and supporting documents.
Following customs control, the customs post employee records the details of the goods application in the register and marks “Release Authorized” using a personal numbered seal.
Thus, submission of applications in paper-based format creates conditions conducive to corruption-related offenses between specialists and FEA participants.
Recommendations:
1) To amend Decision No. 263 of the Customs Union Commission dated 20 May 2010 in terms of automating the process for receiving electronic applications for goods.
2) To consider providing the service “Acceptance of the List of Goods” in electronic form and develop functionality within the KEDEN Information System enabling electronic submission by FEA participants.
Description of the corruption risk:
One of the current issues of tax administration is the appointment of thematic tax audits during the processing of cameral control notifications with the status “violation not remedied.”
Pursuant to subparagraph 24) of paragraph 2 of Article 156 of the Tax Code, a thematic tax audit is conducted to confirm violations identified during cameral control.
To comply with Article 66 of the Administrative Procedural and Process-Related Code of the Republic of Kazakhstan (APPC), SRA employees send taxpayers notifications regarding hearings together with preliminary decisions indicating identified violations.
Preliminary and final decisions are delivered through the Documentolog system (EDMIS), in person, or by mail.
Delivery of decisions in paper-based format creates conditions conducive to corruption-related offenses between specialists and taxpayers.
Not all taxpayers are connected to EDMIS, creating delays and procedural risks. In some cases, taxpayers avoid receiving decisions, which creates opportunities for manipulation, lack of transparency, and improper benefits.
Recommendations:
To implement the possibility of sending SRA decisions through the Tax Administration Information System (ISNA) with automatic SMS notifications to taxpayers.
This functionality will ensure equal access to information, improve transparency, and reduce corruption risks.
No corruption risks related to other issues arising from the organizational and managerial activities of the Department, agreed upon with the relevant specialized divisions of the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan, were reviewed during the period of the internal corruption risk analysis.
Appendix: Risk Map.
Head of the State Revenue
Department of Shymkent B. Karymsakov
Members of the Working Group:
U.Baktybayeva
E.Artykbay
T.Turganbayev
N.Amiraliyev
A.Tolen
N.Sergazin
Zh.Aryntayev
Zh.Beisenbayeva
T.Tlenshin
S. Nurkhan