On 3 September 2026, the Ministry of National Economy of the Republic of Kazakhstan published for public consultation a draft Law “On Amendments and Additions to the Tax Code of the Republic of Kazakhstan”.
The draft proposes changes that may affect tax control, the handling of tax arrears, digital asset transactions, and tax measures applicable to micro and small businesses.
The proposed amendments are aimed at developing investment policy and business financing, encouraging investment activity, refining certain sector-specific tax mechanisms, and improving tax administration.
Below, we look at the key proposed changes and what businesses should take into account.
Desk Audits: Focus on Identified Discrepancies
From 1 January 2027, it is proposed that the results of a desk audit should be based on discrepancies identified from the available data, rather than on assumptions about a potential violation.
What This Means for Businesses
Tax notifications should contain specific discrepancies identified by the tax authorities, which businesses can then reconcile against their accounting records and supporting documents.
Recommended Actions
- Review each tax notification against the discrepancy identified in it.
- Keep documents evidencing the substance of the relevant transactions.
- Where no violation has occurred, provide a reasoned explanation rather than a formal response only.
Electronic Invoices and Travel Restrictions in Cases of Tax Arrears
From 1 January 2027, it is proposed that the issuance of electronic invoices may be suspended where tax arrears exceed the prescribed threshold and have remained unpaid for more than six months.
The draft also proposes strengthening measures for the compulsory recovery of tax arrears. Where arrears exceed 27,000 MCI, a temporary restriction on leaving the country may apply to the head of a legal entity, an individual entrepreneur, or a person carrying out private professional activities. The period for which the arrears must remain unpaid before this measure can be applied would increase from three to four months.
Accordingly, rather than applying all recovery measures, it would be sufficient to suspend debit transactions on bank accounts and issue a collection order. If the debt remains unpaid, the tax authority may apply to the court to impose a travel restriction.
The proposed amendments are intended to improve the effectiveness of tax debt recovery and reduce instances of tax evasion.
What This Means for Businesses
Significant overdue tax liabilities may affect both the ability to issue electronic invoices and the ability of the company’s head to leave the country.
Recommended Actions
- Regularly monitor the amount and payment deadlines of tax liabilities.
- Settle tax arrears promptly or take appropriate steps to resolve them.
- Factor potential restrictions into financial and operational planning.
Digital Assets: Proposed Tax Incentives and Regularisation Measures
The draft proposes introducing tax incentives and an amnesty for individuals who regularise digital assets and transfer them to licensed platforms.
Subject to the applicable conditions, the following measures are proposed:
- exemption from taxation of income from transactions involving digital assets carried out through licensed providers for 2026–2028;
- write-off of tax arrears, penalties and administrative fines relating to the relevant transactions where the assets are transferred to licensed platforms;
- no reassessment of tax liabilities and no audits of transactions for periods before 1 January 2027, provided that the assets are initially declared by 15 September 2027 and 100% of the digital assets are transferred to licensed platforms.
What This Means for Digital Asset Holders
The proposed measures create incentives for the disclosure of digital assets and the transition from unregulated platforms to licensed ones.
Recommended Actions
- Conduct an inventory of digital assets.
- Assess whether the proposed tax amnesty may apply.
- Ensure full disclosure and transfer of the assets within the prescribed deadlines.
- Retain documents evidencing the origin and movement of the assets.
Tax Audits of Micro and Small Businesses
The draft provides for special transitional measures for micro and small businesses, including:
- a moratorium on certain forms of tax control in respect of tax reporting for periods before 1 January 2026, subject to specified exceptions;
- restrictions on claims by tax authorities: tax authorities would not be able to bring claims seeking to invalidate transactions or to register/re-register micro and small businesses in respect of transactions carried out before 1 January 2026, except in cases based on law enforcement materials;
- write-off of specified penalties and fines where the relevant tax arrears are paid within the prescribed period;
- cessation of penalty accrual on taxes and other payments not paid when due for the period from 1 January to 31 December 2026, subject to specified exceptions.
What This Means for Micro and Small Businesses
The draft proposes a package of transitional measures aimed at reducing the tax burden and tax control risks associated with previous periods for micro and small businesses.
Recommended Actions
- Check for any tax arrears, penalties and fines outstanding as at 1 January 2026.
- Assess whether the proposed write-off measures may apply.
- Take into account the exceptions to the moratorium and the cessation of penalty accrual.
- Ensure that current tax reporting is accurate and that all mandatory payments are made on time.
What Businesses Should Consider
The proposed amendments cover several areas of tax regulation — from desk audits and tax debt recovery to digital asset transactions and special measures for micro and small businesses.
As the amendments remain at the draft stage, businesses should monitor the further progress of the legislative process and assess their potential impact on tax compliance, financial planning and day-to-day operations.
Need to Assess the Potential Impact on Your Business?
The REVERA Kazakhstan team can help assess which of the proposed changes may be relevant to your business and identify the issues to consider as part of your tax and operational planning.