Risk of Double VAT in Cross-Border Trade - FCHAIN

Risk of Double VAT in Cross-Border Trade

The development of e-commerce is expanding opportunities for Kazakhstan businesses to enter new markets and reach customers outside the country. At the same time, cross-border sales continue to involve a number of practical issues that directly affect manufacturers, suppliers, and sellers. One of the most sensitive issues for Kazakhstan sellers is the risk of paying VAT twice when selling goods through cross-border trade. This issue was discussed on August 20 in Almaty during the practical session “Marketplaces 2026: Labelling, Export, and New E-Commerce Rules for Kazakhstan Businesses.” The event brought together representatives of government authorities, the National Chamber of Entrepreneurs of the Republic of Kazakhstan “Atameken,” labelling operators, marketplaces, industry associations, and businesses. The participation of these stakeholders made it possible to consider e-commerce issues from the perspectives of the various parties directly involved in the relevant processes. The discussion was not limited to taxation. Participants also considered digital product labelling, marketplace requirements, cross-border supplies, and export opportunities within the EAEU. Particular attention was paid to practical challenges faced by Kazakhstan sellers operating through online marketplaces. These included the risk of double VAT payment, compatibility between labelling systems, disruptions in the SPOT system, and requirements imposed by major marketplaces. The discussion therefore covered several interconnected areas of e-commerce, ranging from taxation and labelling to the organization of cross-border supplies and access to EAEU markets. Following the session, a list of business barriers and proposals was prepared for further consideration with the Ministry of Trade and Integration of the Republic of Kazakhstan, the Atameken National Chamber of Entrepreneurs, labelling operators, marketplaces, and industry associations.

 

Atameken National Chamber of Entrepreneurs’ Position on Double VAT

Participants paid particular attention to cross-border transactions and the practical issues affecting Kazakhstan sellers operating in foreign markets. Among the challenges discussed were the risk of double VAT payment, compatibility between labelling systems, disruptions in the SPOT system, and requirements imposed by major marketplaces. These issues are particularly relevant to companies that sell goods through online marketplaces and conduct cross-border trade. During the session, the risk of paying VAT twice was identified as one of the most sensitive issues for Kazakhstan sellers. The discussion highlighted the importance of further considering the tax aspects of cross-border e-commerce in light of the practical challenges faced by businesses. The Atameken National Chamber of Entrepreneurs stated its position that a single sale of goods should result in a single tax obligation. In connection with this position, the Chamber raised the issue of double taxation with the Russian financial authorities. As a result, the matter has been brought to the interstate level for further consideration, as it directly affects Kazakhstan sellers operating in foreign markets. The double VAT issue was discussed alongside other barriers affecting cross-border e-commerce, including labelling system compatibility, SPOT system disruptions, and marketplace requirements. Following the session, these and other identified barriers and business proposals were included among the matters to be further considered with the relevant government authorities, labelling operators, marketplaces, and industry associations. Accordingly, the risk of double VAT payment is being addressed not only as a challenge faced by individual sellers but also as one of the broader practical barriers affecting the development of cross-border e-commerce.

 

Other E-Commerce Issues

Taxation was one of the key, but not the only, areas discussed during the practical session. Participants also addressed digital product labelling, cross-border supplies, marketplace requirements, and the development of exports to EAEU member states. These matters are of practical importance to manufacturers, suppliers, and sellers that use online marketplaces to sell goods both domestically and internationally. Particular attention was paid to digital labelling. For participants in cross-border trade, the compatibility of labelling systems remains a relevant issue. Businesses selling goods through online platforms need to take applicable labelling requirements into account, and differences between systems and technical difficulties may create additional challenges for market participants. Disruptions in the SPOT system were another issue raised during the session. This matter was considered alongside double VAT and the compatibility of labelling systems as one of the sensitive issues affecting Kazakhstan sellers. This demonstrates that the development of e-commerce involves not only tax rules but also the stable operation of the tools used in the relevant processes. Export opportunities within the EAEU were also discussed separately. E-commerce can be used by Kazakhstan companies to expand the geographical reach of their sales and enter new markets. At the same time, the issues raised during the session concerning double VAT, labelling, cross-border supplies, and marketplace requirements demonstrate the existence of practical barriers that require further consideration. The position of the Atameken National Chamber of Entrepreneurs is that e-commerce regulation should create opportunities for businesses to enter new markets and reduce the cost of reaching customers rather than create additional barriers. Following the session, the identified barriers and business proposals were compiled for further consideration with government authorities, labelling operators, marketplaces, and industry associations.

 

What Kazakhstan Businesses Should Consider

For companies developing sales through marketplaces and engaging in cross-border supplies, tax and regulatory matters are an important part of their operations. During the practical session, the most relevant issues identified for Kazakhstan manufacturers, suppliers, and sellers included the risk of double VAT payment, digital labelling requirements, compatibility between labelling systems, disruptions in the SPOT system, requirements imposed by major marketplaces, and issues arising from cross-border supplies. Export opportunities within the EAEU were also discussed as a separate area. The issue of double VAT is particularly important for businesses. The Atameken National Chamber of Entrepreneurs stated its position that a single sale of goods should result in a single tax obligation. The Chamber raised the issue of repeated VAT payment with the Russian financial authorities, which means that the matter is subject to further consideration by the relevant stakeholders. Alongside taxation, attention was given to digital labelling and the compatibility of the relevant systems in cross-border trade. Participants also identified disruptions in the SPOT system and the requirements of major marketplaces as issues affecting Kazakhstan sellers. Further consideration therefore covers several areas related to e-commerce and the sale of goods in foreign markets. Following the practical session, a list of existing barriers and business proposals was prepared. These matters are expected to be further considered jointly with the Ministry of Trade and Integration of the Republic of Kazakhstan, the Atameken National Chamber of Entrepreneurs, labelling operators, marketplaces, and industry associations. This means that the issues identified during the session remain under further consideration. Companies operating through marketplaces and engaging in cross-border supplies should therefore follow further developments in these areas. In particular, businesses should pay attention to the results of discussions concerning double VAT, digital labelling, the operation of the SPOT system, and online marketplace requirements, as these were among the practical e-commerce issues identified by participants during the session.

 

FChain Solutions for Businesses

Cross-border e-commerce requires attention not only to the organization of sales but also to the tax, accounting, and contractual aspects of business operations. For companies operating through marketplaces and working with international counterparties, FChain provides a range of relevant services:

• Legal Support for Business — legal advice and support for companies regarding business operations and compliance with the requirements of Kazakhstan legislation.
• Legal Audit — review of company documents and legal aspects of business operations to identify potential risks and inconsistencies.
• Drafting Contracts — preparation and legal review of contractual documentation taking into account the nature of transactions and relationships with counterparties.
• Accounting Recovery — restoration of accounting records and documentation where there are gaps or irregularities in accounting.
• Registration of companies — support with business registration in Kazakhstan and the necessary legal procedures involved in establishing company operations.

Entering foreign markets through online marketplaces requires businesses to pay close attention to taxation, accounting, and the formalization of relationships with counterparties. FChain specialists advise companies on relevant matters and provide accounting and legal services to support business operations in Kazakhstan.

 

 Express Shipments and E-Commerce in the EAEU

Prepared by: Anel Kosmaganbetova

Assistant to the Director

FChain Kazakhstan

 📩almaty@f-chain.com
WhatsApp: +7 771 214 1820