Tax audit is a control measure taken by officials of the state revenue authorities (SRA) to assess compliance with the tax and other legislation of the Republic of Kazakhstan by business entities
Entrepreneurs have the right to appeal the results of tax audits to an authorized body or to a court according to the provisions of the Tax Code and the Administrative Procedural Code (APC).
Judicial practice: An analysis of court decisions over the past 4 years shows that the largest number of lawsuits are related to appeals against the procedural actions of the SRA when appointing tax audit in accordance with the provisions of the APC. In particular, taxpayers equate notices, letters, and hearing protocols to administrative acts.
From July 1, 2021 to the present, administrative courts supported 30% of the claims of business entities in the amount of 2.7 billion tenge out of 107 reviewed cases for a total of 39 billion tenge..
Meanwhile, the courts support actions of the SRA aimed at warning taxpayers (within the Articles 70-73 of the APC) by issuing court decisions in favor of the SRA and recognizing the above actions as interim acts not involving the occurrence of tax obligations.
In this regard, it is important that entrepreneurs provide a full package of primary documents confirming the fact of business operations in a timely manner, in accordance with Article 155 of the Tax Code.
For more details.
https://www.gov.kz/memleket/entities/kgd/press/news/details/979408?lang=ru