Article 192. The procedure for filing a complaint by a taxpayer (tax agent) The Tax Code of the Republic of Kazakhstan
1. The complaint of a taxpayer (tax agent) against the notification of the results of a tax audit is submitted to the authorized body within thirty working days following the day of delivery of the notification of the results of the tax audit to the taxpayer (tax agent).
In this case, a copy of the complaint must be submitted by the taxpayer (tax agent) to the tax authorities that conducted the tax audit and considered the taxpayer's (tax agent's) objections to the preliminary tax audit report.
The date of filing a complaint with the authorized body, depending on the method of filing it, is:
1) in absentia – the date of registration of the complaint by the authorized body;
2) by means of a postal or other communication organization – the date of the stamp of acceptance by the postal or other communication organization.
3) electronically – the date of sending via the web portal.
2. If, for a valid reason, the deadline established by paragraph 1 of this Article is missed, this deadline may be restored by the authorized body reviewing the complaint at the request of the taxpayer (tax agent) filing the complaint.
3. In order to restore the missed deadline for filing a complaint, the authorized body recognizes as a valid reason the temporary disability of the individual in respect of whom the tax audit was conducted, as well as the head and (or) chief accountant (if any) of the taxpayer (tax agent).
The provisions of this paragraph shall apply to individuals in respect of whom a tax audit has been conducted, as well as to taxpayers (tax agents) whose organizational structure does not provide for the presence of persons replacing the above-mentioned persons during their absence.
In this case, the taxpayer (tax agent) must attach to the request for restoration of the missed deadline for filing a complaint a document confirming the period of temporary disability of the persons specified in part one of this paragraph and a document establishing the organizational structure of such taxpayer (tax agent).
4. The request of a taxpayer (tax agent) to restore the missed deadline for filing a complaint shall be satisfied by the authorized body, provided that the taxpayer (tax agent) has filed the complaint and petition no later than ten working days from the date of the end of the period of temporary disability of the persons specified in the first part of paragraph 3 of this Article.
5. A taxpayer (tax agent) who has filed a complaint with the authorized body, before making a decision on this complaint, has the right to withdraw it on the basis of his application in hard copy or in the form of an electronic document, except for the case specified in part three of this paragraph.
The withdrawal of a taxpayer's (tax agent's) complaint does not deprive him of the right to file a second complaint, provided that the time limits established by paragraph 1 of this Article are met.
The taxpayer (tax agent) is not entitled to withdraw the complaint from the date of appointment by the authorized body when considering the complaint of a thematic tax audit until the date of its completion.
The Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII SAM.
President
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 192. Rules of tax accounting of the Code on Taxes and Other Obligatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan
1. Unless otherwise established by this Code, a taxpayer (tax agent) shall maintain tax records in tenge according to the accrual method in accordance with the procedure and conditions established by this Code.
2. The accrual method is an accounting method according to which the results of transactions and other events are recognized upon their completion, including from the date of completion of work, provision of services, shipment and transfer of goods to the buyer or his authorized representative for the purpose of sale or registration of property, and not from the date of receipt or payment of money or its equivalent.
3. Based on the results of the tax period, the taxpayer (tax agent) determines the objects of taxation and (or) objects related to taxation, and calculates taxes and payments to the budget.
4. Accounting for exchange differences, including determining the amount of exchange differences, for tax purposes is carried out in accordance with international financial reporting standards and (or) the requirements of the legislation of the Republic of Kazakhstan on accounting and financial reporting.
5. Inventory accounting is carried out in accordance with international financial reporting standards and/or the requirements of the legislation of the Republic of Kazakhstan on accounting and financial reporting. At the same time, for tax purposes, the value of inventories is determined without taking into account changes in the value of inventories by writing it off to the net realisable value and restoring it to the previously written-off inventory caused by an increase in the net realisable value.
The footnote. Article 192 as amended by the Law of the Republic of Kazakhstan dated 10.12.2020 No. 382-VI (effective from 01.01.2018).
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