The updated Tax Code of the Republic of Kazakhstan, effective January 1, 2026, introduces fundamental changes to the framework of tax audits. This reform is designed to alleviate the administrative burden on businesses, enhance the transparency of oversight procedures, and accelerate the resolution of tax-related disputes.
Key Amendments:
Abolition of scheduled and unscheduled tax inspections
The traditional classification of tax inspections into scheduled and unscheduled has been abolished. Under the new framework, audits are initiated based on a risk-oriented approach, moving away from the previous practice of publishing public inspection lists on the website of the Prosecutor General's Office. It ensures that tax control is more targeted, systematic.
Limitation of comprehensive tax audits
Comprehensive audits will be assigned based on the Tax Burden Ratio (TBR). If a taxpayer’s TBR is at least 90% of the upper threshold for their specific industry average, they will be exempt from a comprehensive audit for the corresponding period.
Exceptions apply in the following instances:
upon the taxpayer's own request;
based on grounds stipulated by the Criminal Procedure Code of the Republic of Kazakhstan;
to fulfill requirements issued by the Prosecutor’s Office.
The suspension of the limitation period
The statute of limitations for the assessment of taxes and other obligatory payments is officially suspended for the duration of a tax audit. It remains in effect from the commencement date of the audit until the final execution of the notification detailing the audit results.
Specific rules apply to periods where the statute of limitations is nearing its end at the time an audit begins if less than 30 calendar days remain before the expiration of the limitation period
Delivery of orders and appeal
The official order to appoint a tax audit must be served to the taxpayer within three working days of its issuance.
Filing an appeal against an audit order while the inspection is ongoing does not result in the suspension of the audit.
Limitation of requirements for providing documents
For small and microbusiness entities:
the requirement to provide documents as part of the audit can be served no more than twice;
Deadline to fulfill the claim has been reduced to 10 working days (with the possibility of extending it to 30 working days at the request of the taxpayer).
These measures are aimed at reducing the bureaucratic burden and speeding up procedures.
Moratorium on inspections of small business
Effective January 1, 2026, a moratorium on tax audits for micro and small business entities has been introduced (taking into account exceptions provided for by law).
In general, the changes create a more transparent, digitalized and predictable tax control system focused on supporting honest business and reducing administrative barriers.