Regulatory updates - Kazakhstan

Kazakhstan introduced a pre-filled VAT return service (Form 300.00), which automatically populates VAT declarations using data from government information systems. The service relies on data from electronic invoices (ESF), taxpayer accounts, and customs declarations to support VAT reporting.

Functionality of the service

The system aggregates transactional and tax data submitted by taxpayers and uses it to pre-populate VAT returns. This aims to simplify the filing process and reduce administrative burdens, while also improving consistency between reported data and underlying transactions.

The pre-filled data is updated with a one-day delay, meaning that recently issued electronic invoices or submitted VAT deduction notifications will only appear in the system on the following day.

Accuracy and taxpayer responsibility

Despite the automation, taxpayers remain fully responsible for the accuracy and completeness of the data used in their VAT returns. The system relies on confirmed VAT deduction notifications, which must be completed carefully to ensure correct reporting.

Any changes or corrections made to the underlying data after submission may impact VAT return outcomes, including desk audit results and the issuance of compliance notifications.

Kazakhstan's 2026 Tax Code reform introduces a fundamental change to VAT credit management, shifting from automatic crediting to an active, system-driven allocation process within the IS ESF e-invoicing platform. Here are the main implications for taxpayers:

From automatic to managed VAT crediting

Under the new rules, VAT credit is no longer an automatic outcome of receiving an electronic invoice. Taxpayers must now actively select which incoming e-invoices are used for credit purposes within IS ESF, either individually or in bulk for an entire reporting quarter. For each selected invoice, the system produces a notification confirming the invoice registration number, the VAT amount credited, and the relevant tax period. Note that VAT can only be credited if it is confirmed in the IS ESF system before submitting the VAT declaration.

Partial VAT allocation and adjustments

The new mechanism allows taxpayers to partially credit VAT from a single e-invoice, spreading it across different reporting periods rather than claiming the full amount at once. This is particularly useful where goods or services are re-invoiced, reallocated, or consumed in phases, ensuring VAT recovery reflects actual business activity rather than immediate full recovery. Previously allocated amounts can also be adjusted upward or downward over time, as long as changes are properly recorded within IS ESF.

Compliance implications and VAT control

The new mechanism is particularly relevant for businesses involved in re-invoicing, pass-through costs, agency models, and complex supply chains. By allowing VAT to remain temporarily uncredited, Kazakhstan prevents premature VAT recovery where costs are intended to be on-charged, while giving tax authorities greater visibility over deferred and partial VAT credit claims.

To meet these requirements, businesses will need to update their VAT accounting procedures, align ERP systems with IS ESF workflows, and ensure closer coordination between tax, finance, and IT functions. Errors or omissions in invoice selection or allocation may directly impact VAT recovery and invite scrutiny from the tax authorities.

On December 1, 2025, Kazakhstan’s Ministry of Finance and the Ministry of AI and Digital Development issued a joint order amending the rules and timelines for the Digital VAT pilot project. Initially scheduled to end on December 31, 2025, the pilot is now extended through December 31, 2026.

Obligations

The pilot project aims to modernise VAT refund processes by leveraging the Digital Tenge system and electronic invoicing. Under the updated rules:

• State revenue authorities will provide clarifications, transmit data to the Digital Tenge system, process payment information, and confirm VAT refund amounts.
• VAT refunds under the pilot are processed within 15 working days instead of the standard 55–75 days, without tax audits.
• Taxpayers participating in the pilot must use digital tenge with VAT marking, which restricts funds for specific purposes.
• Payment documents must include the registration number of the relevant e-invoice. For certain budget codes, taxpayers must indicate the customs declaration number or supporting document details.
• Prepayments under electronic contracts require the contract number in both the payment order and the electronic invoice.
• Digital tenge marked for VAT cannot be used for other purposes or withdrawn as cash.

System operations

Payments are processed through second-tier banks, with VAT amounts marked and routed via the Digital Tenge system. The National Bank ensures settlement by transferring redeemed digital tenge to the Unified Treasury Account.

Impact on electronic invoicing

If VAT is paid in digital tenge, electronic invoices cannot be revoked except under specific conditions. Additional rules apply for corrections and cancellations of invoices linked to VAT payments.

Effective period

The order takes effect on December 21, 2025, and applies retroactively to relationships arising since October 7, 2024, until December 31, 2026.