In 2026, the VAT rate in Kazakhstan is 16%; at the same time, claims for the refund of excess VAT submitted before January 1, 2026, are reviewed under the previous Tax Code and within the time limits prescribed therein (Article 833 of the Tax Code of the Republic of Kazakhstan).
What VAT Means for an Accountant
In practice, VAT cannot be regarded solely as an amount stated in an invoice or source document. It is part of tax accounting, in which the accountant determines the nature of the transaction, verifies the documents, correctly records the calculated amounts, and prepares the tax return.
For each transaction, it is important to determine consistently:
- whether the transaction constitutes taxable turnover;
- which taxation procedure applies to the transaction;
- whether there are documents confirming its substance and recognition in the accounting records;
- in which tax period the transaction must be included in the reporting;
- whether VAT payable or an excess amount that may be claimed for refund arises.
The accountant determines the rate, the grounds for exemption, the offset procedure, and the reporting deadline under the provisions that apply specifically to the transaction in question. Applying an exemption or another special procedure based solely on the name of the goods, services, or agreement is risky: the actual substance of the transaction, the status of its participants, and supporting documents are relevant.
Transitional transactions require particular attention. When recording them, the date on which the turnover occurred, the period in which documents were issued and received, and the time when the relevant tax liability arose must be taken into account. The change in the rate from 2026 does not in itself replace the analysis of a specific transaction.
When the Issue of Refunding Excess VAT Arises
Excess VAT does not mean that funds are automatically transferred from the budget. To handle such an amount, the accountant must determine the applicable procedure, correctly report the data in the tax return, and prepare documents supporting the amount claimed.
In 2026, claims must first of all be distinguished by their submission date. If a tax application or claim for the refund of excess VAT was submitted before January 1, 2026, it is reviewed in accordance with the procedure and within the time limits established by the Tax Code dated December 25, 2017 (Article 833 of the Tax Code of the Republic of Kazakhstan).
This transitional rule applies specifically to applications and claims received before the specified date. Therefore, it is important for the accountant to retain confirmation of the document’s submission date, its registration details, and the acknowledgment of receipt. Claims submitted from January 1, 2026, onward are governed by the regulations in effect on their submission date.
Article 424 of the Tax Code of the Republic of Kazakhstan cannot be cited when calculating the VAT refund period. This article regulates a different matter: the declaration of assets and liabilities is submitted at the place of residence or stay by September 15 of the year in which the obligation to submit it arose (Article 424 of the Tax Code of the Republic of Kazakhstan). This provision does not apply to the VAT return or the commencement of the excess VAT refund period.
To avoid mixing different procedures, it is advisable to record separately in the refund working file the tax period, the tax return filing date, the claim submission date, the applicable version of the legislation, and the list of supporting documents. This procedure helps to apply the transitional provision correctly and reconcile the accounting information with the submitted reporting.
Special Procedure for Grain Market Participants
The pilot project for the simplified refund of excess VAT to grain market participants operated in Kazakhstan from December 1, 2021, to June 30, 2024. Consequently, it is incorrect to present it as a special refund procedure in effect in 2026.
The terms of the pilot project, including the refund options provided therein, the bank guarantee, desk audit, export requirements, and the submission of additional information, applied to the project implementation period. They must not be used in 2026 as an independent basis for selecting a procedure or calculating the refund period.
If the organization’s accounting files still contain documents related to participation in this project, the accountant may use them to support transactions for the relevant period. However, the project’s historical documents must be kept separate from tax returns and claims submitted for 2026 transactions.
It is particularly important not to carry previous time limits and criteria over into current procedures merely because they remain in memos, templates, or accounting system settings. The project end date makes it possible to assign its rules unambiguously to a completed period.
For claims submitted before January 1, 2026, the applicable procedure is determined with due regard to the transitional provision of Article 833 of the Tax Code of the Republic of Kazakhstan. However, this article neither reinstates the completed pilot project nor extends its duration: it establishes the procedure for reviewing previously submitted tax applications and claims (Article 833 of the Tax Code of the Republic of Kazakhstan).
What to Check Before Submitting the Tax Return and Claim
Before submitting the reporting, the accountant should reconcile the tax register, tax return, personal account, and documents supporting the reported amounts. If a refund is claimed, the period in which the excess arose, the claim submission date, and the version of the legislation applicable in view of the transitional provisions must be checked separately.
The working review may include the following actions:
- reconcile turnover and VAT amounts in the accounting registers with the tax return figures;
- check the details of source documents and the tax period in which they were recorded;
- separate current transactions from corrections and documents relating to previous periods;
- check the submission date of the refund claim;
- remove references to the completed grain market pilot project from the current procedure;
- do not use Article 424 of the Tax Code of the Republic of Kazakhstan to determine the time limits for a VAT return or refund.
If the accounting system does not accept the tax return file, the type of document selected, the reporting period, the file format, and the completion of mandatory details should first be checked. The program’s technical message must be considered in connection with the specific file and its details, without using it as a substitute for reviewing the tax content of the return.
Before submission, it is advisable to retain the tax return file in the form in which it was submitted, the acknowledgment of receipt, and information about the submission date. When amending reporting, it is also useful to retain the previous version and a brief explanation of the reason for the change. This makes it possible to reconstruct the sequence of actions and confirm which document was submitted to the tax authority.
Transactions under investment contracts concluded before January 1, 2026, should be checked separately. The VAT exemption for imports of raw materials and supplies under the relevant investment contract remains in effect until the contract expires, except for contracts for investment priority and strategic projects (Article 839 of the Tax Code of the Republic of Kazakhstan).
For investment priority projects under contracts concluded before January 1, 2026, the contractual terms remain in effect until the contract expires, within the limits established by the transitional provisions. For contracts concluded from January 1, 2018, to January 1, 2026, this applies to tax incentives and the guarantee of stability of tax legislation (Article 837 of the Tax Code of the Republic of Kazakhstan).
For such transactions, the accountant must link the applicable condition to the specific contract and its term. The existence of a transitional provision does not mean that the same procedure may be applied to all import transactions or all investment projects.
Frequently Asked Questions
What VAT rate applies in Kazakhstan in 2026? — The standard VAT rate is 16%. When recording transitional transactions, the accountant must determine the period and taxation procedure applicable to the specific transaction.
Can excess VAT be refunded automatically from the budget? — No. The amount must be correctly reported in the tax return, and the prescribed procedure applies to the refund, taking into account the claim submission date.
How are claims submitted before 2026 reviewed? — Tax applications and claims for the refund of excess VAT submitted before January 1, 2026, are reviewed under the rules and within the time limits of the previous Tax Code (Article 833 of the Tax Code of the Republic of Kazakhstan).
Does Article 424 of the Tax Code of the Republic of Kazakhstan determine the deadline for submitting a VAT return? — No. It establishes the deadline for submitting the declaration of assets and liabilities—by September 15 of the relevant year (Article 424 of the Tax Code of the Republic of Kazakhstan).
Is the pilot project for grain market participants in effect in 2026? — No. The project implementation period ended on June 30, 2024, so its terms cannot be presented as a procedure in effect in 2026.
What should be done if the accounting system does not accept the tax return file? — Check that the correct document type has been selected, the reporting period has been specified correctly, the required format has been followed, and the mandatory file details have been completed.
Does the exemption under an existing investment contract remain in effect? — For an investment contract provided for by Article 839 of the Tax Code of the Republic of Kazakhstan and concluded before January 1, 2026, the VAT exemption for imports of raw materials and supplies remains in effect until the contract expires, subject to the established exceptions (Article 839 of the Tax Code of the Republic of Kazakhstan).
Sources
- Tax Code of the Republic of Kazakhstan: transitional provisions concerning claims for the refund of excess VAT
- Tax Code of the Republic of Kazakhstan: deadline for submitting the declaration of assets and liabilities
- Rules and time limits for implementing the pilot project for the simplified refund of excess VAT to grain market participants