Electronic Invoices (E-Invoices)

1. I have worked under a simplified tax declaration and I am not a VAT payer. In 2026, I will also not be a VAT payer. Do I need to issue an electronic invoice?

Answer: According to provisions of Article 99 of the Tax Code (effective January 1, 2025), the taxpayers applying a special tax regime are not subject to VAT registration.
The taxpayers using a special tax regime based on a simplified tax declaration, while being non-VAT payers, are required to issue an invoice. However, an invoice is not required in the following cases:

1) the sale of goods, works, and services, the payments for which are made:

- with presentation to the buyer of a cash register receipt and/or through payment terminals;

- with presentation to the buyer of a receipt for goods, works, and services from a special mobile application. In this case, at the request of the buyer, the receipt must contain the identification number of such buyer of goods, works, services;

2) the sale of goods, works, services to individuals, the payments for which are made with electronic money or using electronic payment means;

3) the payments through second-tier banks, a post operator for utilities and communication services provided to an individual;

4) the payment of passenger transportation on rail or air transport with a hard copy ticket, electronic ticket or electronic travel document;
5) the gratuitous transfer of goods, gratuitous performance of work, provision of services to an individual who is not an individual entrepreneur or a person engaged in private practice;

6) the sale of financial transactions provided for in Article 477 of the Tax Code.

2. Why should I issue myself an electronic invoice for non-resident services?

Answer: The introduction of electronic invoices for transactions related to the purchase of works and services from non-residents is associated with complex administration of such transactions. The absence of information in information systems prior to the submission of VAT Declaration (Form 300.00) leads to distorted information on the VAT offset amount and poor desk audit performance.
Electronic invoices for VAT for non-residents will be issued to the taxpayer after the date of payment of the non-resident's VAT to the budget, but no later than five calendar days after such payment date. In turn, the VAT payer has the right to offset the VAT amount for the non-resident based on the issued electronic invoice based on the date it is issued. Thus, the proposed mechanism will allow for the unambiguous determination of the date of VAT amount offset, which will facilitate the tax administration and reduce the number of desk audit notifications. An electronic invoice for a non-resident can be issued both on the IS E-Invoice portal and through the accounting systems used by non-residents (for example, 1C).

3. If an organization provides services and sells goods only to individuals, is it required to issue invoices?

Answer: The organization has the right not to issue invoices in the following cases:
1) the sale of goods, works, services, payments for which are made:
- with the presentation to the buyer of a cash register receipt and (or) through payment terminals;

2) the sale of goods, works, services to individuals, payments for which are made with electronic money or using electronic payment means;

3) sales to individuals who use the purchased goods for personal, family, household or other use not related to entrepreneurial activity (final consumption). However, if necessary, it is possible to issue an electronic invoice for the sale of goods to individuals for the entire turnover for the day, for each type of goods (clause 70 of Order No. 629).

4. When does the suspension of electronic invoice issuance occur?

Answer: The suspension of the issuance of electronic invoices shall be carried out by the tax authority within one business day following the day of:
1) the failure to execute or the issuance of a decision by the tax authority to recognize as unexecuted a notification confirming the actual turnover of goods, performance of work and provision of services;

2) the failure to execute a notification confirming the location of the taxpayer (tax agent);

3) the expiration of the deadline for filing VAT tax returns by a VAT payer who has not independently submitted such tax returns during the previous six months;

4) the suspension by the VAT payer of filing tax returns for such tax until the date of resumption of filing such tax returns;

5) the entry into force of a court decision on invalidating the registration of an individual entrepreneur or a legal entity;

6) the entry into force of a court decision on invalidating the re-registration of a legal entity;

7) the entry into force of a court decision on recognizing an individual who is the first director of a legal entity or an individual entrepreneur, incapacitated or partially incapacitated;

8) the entry into force of a judicial act recognizing an individual who is the first director of a legal entity or an individual entrepreneur as missing;
9) the receipt of information from the register of numbers on the death or recognition of an individual who is the first director of a legal entity or an individual entrepreneur as deceased;

10) the entry into force of a judicial act by which an individual who is the first director or the sole founder (participant) of a legal entity or an individual entrepreneur is found guilty of committing a criminal offense related to the activities of this legal entity or individual entrepreneur under Articles 216, 238 or 245 of the Criminal Code of the Republic of Kazakhstan;

11) the issuance of a resolution on the search for an individual who is the first director of a legal entity or an individual entrepreneur;

12) the receipt of information that the purpose of stay is not related to the implementation of labor activities in the Republic of Kazakhstan or the permitted period of stay in the territory of the Republic of Kazakhstan of an individual - a foreigner or a stateless person who is the first director or the sole founder (participant) of a legal entity or an individual entrepreneur has expired;

13) the inclusion of an individual entrepreneur in the register of inactive taxpayers;

14) the inclusion in register of inactive taxpayers of a taxpayer whose first director or sole founder (participant) is the first director or sole founder (participant) of a legal entity - VAT payer;

15) the failure of the taxpayer to comply with the notification of alleged discrepancies based on the results of a desk audit.