When an organisation is liquidated in 2026, the accountant must take into account the limitation period for tax obligations: as a general rule, it is three years, while for designated categories of taxpayers it is five years (Article 65 of the Tax Code of the Republic of Kazakhstan).
How the Liquidation of an Organisation Begins
The accountant’s work must be based on a duly executed liquidation resolution. It should be used to determine the date on which the resolution was adopted, the persons responsible for the procedure and the powers of those who will sign documents on behalf of the organisation.
Before beginning the settlements, it is advisable to perform a full reconciliation of the accounting records. The accountant must establish:
- what assets the organisation actually has;
- to whom the organisation has obligations;
- who owes money or property to the organisation;
- whether there are any outstanding contracts, advances or accountable amounts;
- whether all source documents have been recorded in the accounts;
- what reports and calculations still need to be submitted;
- whether there are any discrepancies between the accounting registers, contracts and source documents.
Banking transactions, cash, inventories, fixed assets, intangible assets, loans, settlements with founders and mutual settlements with counterparties require particular attention. The existence of a liquidation resolution does not in itself mean that the accountant may automatically write off debts or property: each transaction requires a proper basis and supporting documents.
When reviewing tax calculations, it is necessary to take into account the period for which the tax authority is entitled to calculate, assess or review taxes and payments to the budget, and during which the taxpayer is required to submit tax returns, is entitled to amend them or claim an offset or refund of taxes, payments and penalties. As a general rule, the limitation period begins after the end of the relevant tax period (Article 65 of the Tax Code of the Republic of Kazakhstan).
What an Accountant Should Do During Liquidation
It is advisable to begin the practical work with an inventory count and reconciliations. The actual availability of property must be compared with the accounting records, reconciliation statements must be requested from counterparties, accounts receivable and accounts payable must be reviewed, and missing source documents must be collected.
The subsequent sequence depends on the decisions made by the persons conducting the liquidation and the actual status of settlements. The accountant’s working checklist usually includes:
- Recording account balances as at the commencement date of the procedure.
- Reviewing contracts and unfulfilled obligations.
- Confirming accounts receivable and accounts payable.
- Documenting transactions involving the organisation’s assets.
- Recording settlements with employees, counterparties and other persons.
- Preparing accounting registers and reports for the relevant periods.
- Compiling an archive of source documents, registers and personnel documents.
All write-offs and adjustments must be substantiated. For example, an entry in an accounting memorandum alone is insufficient if the transaction requires a resolution, certificate, contract, payment document or other evidence.
It is also important for the accountant to distinguish between their own functions and the powers of the persons managing the liquidation. Decisions on the disposal of property, recognition of claims and performance of settlements must be made by authorised persons. The task of the accounting department is to properly document and record these decisions in the accounts, not to substitute its own decisions for them.
When preparing tax returns, it is necessary to determine which periods are covered by the limitation period. The five-year period applies, in particular, to large business entities, subsoil users, certain residents with obligations under Chapter 33 of the Tax Code of the Republic of Kazakhstan and VAT payers in respect of import tax paid using the offset method. For taxpayers that do not fall within the listed categories, the period is three years (Article 65 of the Tax Code of the Republic of Kazakhstan).
Special Rules for an Insurance Organisation
When an insurance or reinsurance organisation is liquidated, the accountant must separately review the tax accounting of insurance and reinsurance contracts. For the reporting tax period from 1 January to 31 December 2026, transitional provisions apply to the recognition of certain income and deductions related to the transition to International Financial Reporting Standard 17 “Insurance Contracts” (Article 844 of the Tax Code of the Republic of Kazakhstan).
Income for this period includes the increase in retained earnings from previous years in the annual audited financial statements for 2023 resulting from the transition to IFRS 17. Account is also taken of the negative difference prescribed by the Tax Code of the Republic of Kazakhstan between the net profit according to the reporting prescribed by the National Bank, subject to the required approvals, and the net profit in the audited financial statements for 2023, 2024 and 2025 (Article 844 of the Tax Code of the Republic of Kazakhstan).
An insurance or reinsurance organisation is entitled to deduct the decrease in retained earnings from previous years in the annual audited financial statements for 2023 resulting from the transition to IFRS 17. The transitional provisions also cover the prescribed positive difference between the net profit according to the relevant reporting and the net profit reflected in the audited financial statements for 2023, 2024 and 2025 (Article 844 of the Tax Code of the Republic of Kazakhstan).
Therefore, when closing the accounts, ordinary liquidation settlements must be separated from indicators covered by the transitional provisions for 2026. To record them, the accountant will need the annual audited financial statements for 2023, the audited financial statements for 2023–2025 and the relevant reporting prescribed by the National Bank.
The provisions concerning such income and deductions also apply to the Export Credit Agency of Kazakhstan. For the differences prescribed by the Tax Code of the Republic of Kazakhstan, account is taken of the reporting prescribed by the authorised body for the regulation of trade activities and approved by the state authorities listed in the Code (Article 844 of the Tax Code of the Republic of Kazakhstan).
Articles 65, 67 or 85 of the law on insurance activities must not be cited as articles of the Tax Code: the article numbers refer to different regulatory acts and govern different matters. For the tax aspects of liquidation, Article 65 of the Tax Code of the Republic of Kazakhstan establishes limitation periods, while the special transitional provisions for insurance and reinsurance contracts are set out in Article 844 of the Tax Code of the Republic of Kazakhstan.
Liquidation of an Organisation and the Labour Code of the Russian Federation
The query “liquidation of an organisation under the Labour Code of the Russian Federation” relates to Russian legislation. For an organisation registered and operating in Kazakhstan, the Labour Code of the Russian Federation does not constitute a legal basis for processing personnel matters.
A Kazakhstani employer must apply the laws of the Republic of Kazakhstan as in force on the date of the relevant action. Russian notification periods, forms of personnel decisions and payment procedures must not be transferred to the documents of a Kazakhstani organisation.
It is important for the accountant to coordinate personnel matters with the responsible persons: identify the employees concerned, review accruals, unused leave, outstanding payments and the documents for each employee. Amounts and deadlines are calculated in accordance with the applicable laws of the Republic of Kazakhstan and the organisation’s documents.
Tax calculations must be considered separately from personnel documentation. Within the limitation period, the organisation is required to submit tax returns and is also entitled to amend or supplement them or claim an offset or refund of taxes, payments to the budget and penalties (Article 65 of the Tax Code of the Republic of Kazakhstan).
Frequently Asked Questions
Can accounting cease immediately after the liquidation resolution is adopted? — No. As long as transactions involving assets, obligations and settlements continue, they must be documented and recorded in the accounts.
Must all accounts receivable be written off automatically? — No. A write-off requires a proper basis and supporting documents; the liquidation resolution itself is not such a universal basis.
What limitation period should be applied to tax obligations? — In 2026, the general period is three years. A five-year period is established for the categories of taxpayers listed in the Tax Code of the Republic of Kazakhstan (Article 65 of the Tax Code of the Republic of Kazakhstan).
When does the limitation period begin? — As a general rule, it begins after the end of the relevant tax period. The article establishes a special procedure for certain cases (Article 65 of the Tax Code of the Republic of Kazakhstan).
Do the rules of the Labour Code of the Russian Federation apply when a Kazakhstani organisation is liquidated? — No. The personnel and settlement documents of a Kazakhstani organisation are prepared in accordance with the laws of the Republic of Kazakhstan.
What additional matters should an insurance organisation review in 2026? — It must review the recognition of income and deductions under the transitional provisions for insurance and reinsurance contracts for the period from 1 January to 31 December 2026 (Article 844 of the Tax Code of the Republic of Kazakhstan).
Can an article number be used without specifying the regulatory act? — The regulatory act should be specified in documents and working explanations because identical article numbers in different laws govern different matters.
Legal Basis
- Article 65 of the Tax Code of the Republic of Kazakhstan — limitation periods for tax obligations and claims.
- Article 844 of the Tax Code of the Republic of Kazakhstan — transitional provisions on income and deductions under insurance and reinsurance contracts for 2026.