Article 51. The procedure for submitting a document by a tax authority to a taxpayer (tax agent) The Tax Code of the Republic of Kazakhstan

Home / Codes / Article 51. The procedure for submitting a document by a tax authority to a taxpayer (tax agent) The Tax Code of the Republic of Kazakhstan

1. The document is submitted to the taxpayer (tax agent) by an official of the tax authority by personally handing it over against signature on paper or sending it in another way confirming the fact of sending and receiving.

2. The document is considered to have been served, unless otherwise established by this Code, when sent in the following ways, confirming the fact of sending and receiving:

1) by means of a postal or other communication organization by registered mail with a notification – from the date of the taxpayer's (tax agent's) mark in the notification of the postal or other communication organization.

At the same time, a paper document is delivered by a postal or other communication organization within ten working days from the date of its acceptance.;

2) electronically – from the date of delivery of the electronic document to:

a web application, a special mobile application, and/or a tax mobile application;

user's account on the web portal with sending a short text message to a cellular subscriber number registered on the web portal;

another object of informatization of the tax authority.

This method applies to a taxpayer (tax agent) registered at the relevant informatization facility.;

3) through a State Corporation – from the date of receipt of the paper document in person.

3. When a postal or other communication organization returns a document sent to a taxpayer (tax agent) by registered mail with a notification, the date of delivery of such document is the date of the tax survey.

4. If a postal or other communication organization returns a notification on the results of a tax audit or a notification on the amounts accrued during the liquidation period sent based on the results of a tax audit completed on the basis of a tax survey report, the date of such return is considered to be the date of delivery.

5. In the event of a refusal by a taxpayer (tax agent), an official of the tax authority shall draw up an act of refusal to receive a decision of the tax authority (signed on a copy of the decision of the tax authority) (hereinafter referred to as the act of refusal).

The act of refusal is drawn up with the participation of witnesses.

6. The act of refusal states:

1) place and date of compilation;

2) the number and date of the decision of the tax authority, which was refused to be received or signed by the taxpayer (tax agent).;

3) last name, first name and patronymic, type and number of the identity document, identification number and address of the place of residence of each person understood;

4) the reasons for the refusal of the taxpayer (tax agent).

The act of refusal is signed by the official of the tax authority who drafted it, and by the witnesses.

An official of the tax authority has the right to attach photographs and negatives, video recordings or other materials made during the commission of the action to the act of refusal.

7. The provisions of this article shall also apply when a tax authority submits a decision to other persons in order to ensure the implementation of this Code and other legislation of the Republic of Kazakhstan, the control over compliance with which is entrusted to the tax authority.

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 51. The procedure and conditions for granting deferral or installment payment of taxes and (or) fees of the Code on Taxes and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

1. Deferral or installment payment of taxes and (or) fees is a change in the deadline for payment of taxes and (or) fees, if there are grounds provided for in this Article, respectively, with a one-time or phased payment of taxes and (or) fees. At the same time, a schedule for fulfilling the tax obligation is attached to the decision on granting installments for the payment of taxes and (or) fees.

A deferral with a one-time payment of taxes and/or fees is granted for a period not exceeding six months.

Installments with monthly or quarterly payment of taxes and/or fees in equal installments are provided for a period not exceeding three years. At the same time, installments for the payment of taxes and (or) fees for a period of more than one year may be provided only against the pledge of immovable property of the taxpayer and (or) a third party and (or) under a bank guarantee.

A deferral or installment plan may be granted for one or more taxes and/or fees.

2. A deferral or installment payment of taxes and (or) fees may be granted to a taxpayer whose financial situation does not allow him to pay taxes and (or) fees within the prescribed period, however, there are sufficient grounds to believe that the possibility of paying them will arise during the period for which the deferral or installment payment is provided, if there are one of the following grounds:

1) causing damage to the taxpayer as a result of force majeure (emergencies of a social, natural, man-made, environmental nature, military actions and other circumstances of force majeure);

2) the production and (or) sale of goods, works or services by a taxpayer is seasonal in nature;

3) the property status of an individual who is not registered as an individual entrepreneur (excluding property that cannot be levied in accordance with the legislation of the Republic of Kazakhstan) excludes the possibility of a one-time tax payment;

4) the court's decision on the application of the debt restructuring procedure;

5) the main activity of the taxpayer belongs to the branch of the economy of strategic importance according to the laws of the Republic of Kazakhstan;

6) submission of additional tax reports by the taxpayer;

7) the taxpayer's consent to the amounts of accrued taxes and (or) fees indicated in the notification of the audit results. The provisions of this subparagraph do not apply to taxpayers whose period from the date of registration as a taxpayer to the date of filing an application for a deferral or installment plan is less than five years.

3. The following documents are attached to the application for changing the deadline for fulfilling the tax obligation to pay taxes and (or) fees:

1) a list of the taxpayer's debtors, indicating the prices of contracts concluded with the relevant debtors (the amount of other obligations and the grounds for their occurrence), and the timing of their execution, as well as copies of these contracts (documents confirming the existence of other grounds for the obligation). The provisions of this subparagraph do not apply to an individual who is not registered as an individual entrepreneur or a person engaged in private practice.;

2) documents confirming the existence of grounds for changing the deadline for payment of taxes and (or) fees specified in paragraph 4 of this Article;

3) documents on the property that may be the subject of pledge, accompanied by an appraiser's report on the assessment of the market value of the property being pledged, or a bank guarantee agreement concluded between the guarantor bank and the taxpayer, and a bank guarantee. At the same time, the appraiser's report on the assessment of the market value of the pledged property must be drawn up no earlier than ten working days before the date on which the taxpayer submits an application for a deferral or installment plan.

4. Documents confirming the existence of grounds for changing the deadline for payment of taxes and (or) fees on the basis provided for by:

subparagraph 1) paragraph 2 of this Article, – confirmation of the occurrence of force majeure circumstances in relation to the taxpayer by the relevant authorized state bodies;

subparagraph 2) paragraph 2 of this article is a document drawn up by a taxpayer and confirming that in the total income from the sale of goods, works, and services of such a person, the share of his income from industries and activities of a seasonal nature is at least 50 percent;

subparagraph 3) paragraph 2 of this Article, – information on income for the year preceding the date of filing the application, movable and immovable property of an individual, issued by the relevant authorized body not earlier than ten working days before the date of filing the application.

5. A decision to change the deadline for fulfilling a tax obligation to pay taxes and (or) fees or to refuse to change it shall be taken by the body authorized to make such a decision in accordance with Article 50 of this Code within twenty working days from the date of receipt of the taxpayer's application in the form established by the authorized body.

A decision on changing the deadline for fulfilling a tax obligation to pay taxes and (or) fees shall enter into force from the date of its signing.

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A deferral with a one-time payment of taxes and/or fees is granted for a period not exceeding six months.

A deferral or installment plan may be granted for one or more taxes and/or fees.

1) causing damage to the taxpayer as a result of force majeure (emergencies of a social, natural, man-made, environmental nature, military actions and other circumstances of force majeure);

2) the production and (or) sale of goods, works or services by a taxpayer is seasonal in nature;

4) the court's decision on the application of the debt restructuring procedure;

5) the main activity of the taxpayer belongs to the branch of the economy of strategic importance according to the laws of the Republic of Kazakhstan;

6) submission of additional tax reports by the taxpayer;

3. The following documents are attached to the application for changing the deadline for fulfilling the tax obligation to pay taxes and (or) fees:

2) documents confirming the existence of grounds for changing the deadline for payment of taxes and (or) fees specified in paragraph 4 of this Article;

4. Documents confirming the existence of grounds for changing the deadline for payment of taxes and (or) fees on the basis provided for by:

subparagraph 1) paragraph 2 of this Article, – confirmation of the occurrence of force majeure circumstances in relation to the taxpayer by the relevant authorized state bodies;

A decision on changing the deadline for fulfilling a tax obligation to pay taxes and (or) fees shall enter into force from the date of its signing.

6. The decision to refuse to change the deadline for fulfilling a tax obligation to pay taxes and (or) fees must be motivated.

7. The schedule for the fulfillment of a tax obligation may be reviewed on the basis of a reasoned taxpayer's statement.

At the same time, the schedule for fulfilling a tax obligation may be reviewed no more than once.

The footnote. Article 51 as amended by the Laws of the Republic of Kazakhstan dated 03.01.2019 No. 213-VI (effective after ten calendar days after the date of its first official publication); dated 10.12.2020 No. 382-VI (effective from 01.01.2021); dated 20.12.2021 No. 85-VII (effective from 03.01.2022); from 12/21/2022 No. 165-VII (for the procedure of entry into force, see art. 4).

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