Article 87. Restriction on the disposal of property of a taxpayer (tax agent) of the Tax Code of the Republic of Kazakhstan
1. The restriction on the disposal of the taxpayer's (tax agent's) property is carried out by the tax authority in the following cases::
1) non–repayment by a taxpayer (tax agent) of tax arrears in an amount exceeding the maximum amount of tax arrears - within the limits of the amount of tax arrears;
2) appeals by a taxpayer (tax agent), with the exception of a participant in horizontal monitoring, of a notification of the results of a tax audit – within the limits of the amount appealed, reflected in the notifications of the results of the tax audit.
An inventory of the restricted property is made in the presence of the taxpayer (tax agent).
In the absence of the taxpayer (tax agent) at the location indicated in the registration data, confirmed by the act of tax inspection, the inventory of the limited property is carried out without the participation of the taxpayer (tax agent).
2. Are not subject to restrictions in the disposal:
life support facilities;
electrical, thermal and other types of energy;
food products or raw materials with a shelf life and/or shelf life of less than one year.
3. The limited property of a taxpayer (tax agent) transferred (received) for financial leasing or pledged before the termination of the lease and/or pledge agreement is not subject to seizure.
The only dwelling is subject to seizure only on the basis of a judicial act that has entered into legal force.
4. A taxpayer (tax agent) is prohibited from changing the terms of the agreement (extending the term of the agreement, subleasing and/or re-mortgaging) from the date the tax authority restricts the disposal of property until its cancellation.
5. The tax authority cancels the restriction on the disposal of property in the following cases::
1) repayment by a taxpayer (tax agent) of the amounts of tax arrears by paying;
2) cancellation of the notification of the results of the tax audit by a decision of the authorized body or by a judicial act that has entered into legal force in full;
3) appeals of the registering authority for the state registration of property that has been converted (received) into state ownership;
4) adoption of a decision by the authorized body for the management of state property on admission to state ownership.
6. The decision to restrict the disposal of the taxpayer's (tax agent's) property, the act of inventory of the restricted property, and the decision to lift the restriction on the disposal of property are sent to the registration authority and submitted to the taxpayer (tax agent).
The Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII SAM.
President
Republic of Kazakhstan
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