Article 162. The beginning of the tax audit of the Tax Code of the Republic of Kazakhstan

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 1. The date of commencement of the tax audit is the date on which the taxpayer (tax agent) receives the tax authority's order personally against signature, unless otherwise specified in paragraph 6 of this Article.

 2. The order of the tax authority is submitted to the taxpayer (tax agent) within three working days following the day of discharge.

 The taxpayer (tax agent) signs the copy of the tax authority's order on familiarization and receipt, as well as the date and time of receipt.

 The provisions of parts one and two of this paragraph do not apply to thematic tax audits that are not assigned to a specific taxpayer (tax agent).

 3. When conducting a thematic tax audit that is not assigned to a specific taxpayer (tax agent), the taxpayer (tax agent) or his employee who sells goods, performs work or provides services is presented with the original order for review and a copy of it is handed over.

 In the original, the instructions of the tax authority by the taxpayer (tax agent) or his employee who sells goods, performs work or provides services:

 A corresponding entry is made on familiarization with the order of the tax authority and receipt of a copy.;

 the signature, date and time of receipt of a copy of the tax authority's order are given.

 4. In case of refusal of the taxpayer (tax agent) to receive the order of the tax authority, the official of the tax authority:

 1) makes a video recording of the fact of refusal;

 2) makes a corresponding entry on a copy of the tax authority's order;

 3) draws up an act of refusal to receive an order from the tax authority with the involvement of witnesses.

 5. The refusal of a taxpayer (tax agent) to receive an order from a tax authority is not a reason for canceling a tax audit.

 The refusal of a taxpayer (tax agent) to receive an order from a tax authority means that officials of the tax authority are not allowed to conduct a tax audit.

 The provision of part two of this paragraph shall not apply if the taxpayer (tax agent) has the right to refuse access to the territory and (or) premises to officials of the tax authority.

 6. If the taxpayer (tax agent) refuses to receive an order from the tax authority, the date of the beginning of the audit is considered to be the date of drawing up the act of refusal to receive the order.

 7. During the period of the tax audit, it is not allowed to terminate this tax audit due to:

 1) the tax statement of the taxpayer (tax agent);

 2) termination of a criminal case and a tax audit on the grounds provided for by the Criminal Procedure Code of the Republic of Kazakhstan, if the audit is conducted as part of a pre-trial investigation.

 8. If a taxpayer appeals against a tax authority's order during the period of the tax audit, the suspension of such a tax audit is not allowed.

The Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII SAM.

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Republic of Kazakhstan

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From January 1, 2026, to invalidate the Code of the Republic of Kazakhstan dated December 25, 2017 "On Taxes and Other Mandatory payments to the Budget" (Tax Code) in connection with the entry into force of the Tax Code dated July 18, 2025 No. 214-VIII SAM.

Article 162. Information sources of the Code on Taxes and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

1. To determine the objects of taxation and (or) objects related to taxation based on indirect methods, tax authorities, depending on the circumstances, nature and type of activity of the taxpayer (tax agent) being audited, may use the following information:

1) statements from second-tier banks and organizations engaged in certain types of banking operations on the availability and movement of money in the taxpayer's (tax agent's) bank accounts;

2) about the objects of taxation and (or) objects related to taxation, according to the data of authorized state bodies, legal entities, local executive bodies;

3) on the accrual and receipt of amounts of taxes and payments to the budget on the basis of the taxpayer's (tax agent's) personal account, which are subject to comparison with the taxpayer's (tax agent's) accounting data;

4) on taxable objects and (or) objects related to taxation, obtained from tax reporting forms submitted by the taxpayer (tax agent) and his suppliers and buyers for the tax period under review and previous tax periods;

5) on the results of counter-inspections in respect of persons who shipped goods and (or) performed work and (or) provided services obtained through information systems of government agencies, as well as from other sources;

6) received by the tax authority during previously conducted tax audits, including an inventory of the property (other than residential premises) of the taxpayer (tax agent) being audited, which is an object of taxation and (or) an object related to taxation;

7) received by the tax authority based on the results of other forms of tax and customs control.

2. The tax authorities send requests to:

1) banks and organizations engaged in certain types of banking operations;

2) relevant authorized state bodies, local executive bodies and other organizations operating in the territory of the Republic of Kazakhstan;

3) other tax authorities on conducting counter-tax audits on the issue of mutual settlements with suppliers and buyers of the taxpayer being audited;

4) competent authorities of foreign states.

3. The necessary information can also be obtained from the following sources (documented):

1) from customers about the cost of the services performed by the audited taxpayer (tax agent) and from buyers about the cost and quantity of the purchased products;

2) from individuals and legal entities who provided services to the taxpayer (tax agent) being audited, who supplied raw materials, energy resources and auxiliary materials in the field of production and turnover of certain types of excisable goods.

4. The sources of information may vary from case to case, depending on the circumstances, nature, and type of activity of the taxpayer (tax agent) being audited.

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