Penalties for E-Invoices and New VAT Input Credit Rules - FCHAIN

Penalties for E-Invoices and New VAT Input Credit Rules

Starting from 2026, important changes related to Electronic Invoices (ESF) continue to apply to taxpayers in Kazakhstan. In addition to liability for late issuance of ESFs, the procedure for determining the tax period in which VAT may be claimed as input tax has also changed. Below are the key rules businesses should be aware of.

 

Deadline for Issuing an Electronic Invoice (ESF)

According to Paragraph 1 of Article 493 of the Tax Code of the Republic of Kazakhstan, an electronic invoice must be issued:

• ~ no earlier than the date of the taxable supply; and
• ~ no later than 15 calendar days after the date of the taxable supply.

For certain types of transactions, the Tax Code establishes special deadlines for issuing ESFs. In such cases, the relevant provisions of Article 493 of the Tax Code should be followed.

 

Penalties for Late Issuance of an ESF

Failure to issue an electronic invoice within the prescribed deadline constitutes an administrative offense. Liability is established by Article 280-1 of the Code of Administrative Offenses of the Republic of Kazakhstan.

First Violation

For a first-time violation, the taxpayer receives a warning. No monetary penalty is imposed.

Repeated Violation

If the same violation is committed again within one year after the administrative sanction was imposed, the following fines apply:

• ~ 20 MCI for small businesses;
• ~ 50 MCI for medium-sized businesses;
• ~ 100 MCI for large businesses.

Therefore, a late-issued ESF does not automatically result in a financial penalty. However, repeated violations within one year are subject to administrative fines, making timely issuance of ESFs essential.

 

New VAT Input Credit Rules Effective from 2026

One of the most significant changes concerns the tax period in which VAT may be claimed as an input tax credit. From 2026, the determining factor is the date the goods, works, or services are received, rather than the invoice issuance date. This means VAT should be recognized as an input tax credit in the tax period corresponding to the date the goods, works, or services are actually received.

 

Corrected Invoices

If a supplier issues a corrected invoice, the VAT should be claimed in the same tax period in which the VAT under the cancelled invoice was originally recognized. An exception applies where the taxable supply date in the corrected invoice differs from that of the cancelled invoice and falls into a different tax period. In such cases, the VAT input credit is recognized in the new tax period.

 

If the Original Invoice Was Issued on Paper

Where an electronic invoice references a previously issued paper invoice, the paper invoice date is considered the invoice issuance date for VAT input credit purposes.

 

Special Cases

The general rule based on the receipt date does not apply in all cases. Paragraphs 2–5 of Article 481 of the Tax Code establish special rules for specific transactions, including:

1. certain import transactions;
2. supplementary invoices;
3. other cases expressly provided by the Tax Code.

In such situations, the VAT input credit period is determined under the applicable special provisions.

 

Key Takeaways for Businesses

To minimize tax risks and avoid administrative liability, businesses should:

1. issue electronic invoices within the statutory deadlines;
2. monitor the actual receipt date of goods, works, and services;
3. properly account for corrected ESFs;
4. apply the special provisions of the Tax Code where applicable.

Although a first-time delay results only in a warning, repeated violations may lead to substantial fines. At the same time, the new VAT input credit rules require greater attention to accounting and tax reporting.

 

Accounting Support for Your Business with FChain

Tax legislation is constantly evolving, making it increasingly difficult for businesses to keep track of regulatory changes. FChain helps companies maintain accounting and tax records in compliance with the legislation of the Republic of Kazakhstan while reducing risks and saving valuable time. We offer:

• Comprehensive accounting services for LLPs and sole proprietors;
• Accounting restoration services;
• Preparation and submission of tax and financial reports;
• Payroll calculation and HR support;
• Business registration and ongoing corporate support.

Entrust your accounting to FChain and focus on growing your business. We ensure accuracy, compliance, and timely fulfillment of all accounting and tax obligations.

 

New Rules for Digital Condominiums in Kazakhstan

Prepared by: Moldir Mukhtar

Business Development Specialist

FChain Kazakhstan

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