VAT on Imports from the EAEU: Advance Payment from 2027 - FCHAIN

VAT on Imports from the EAEU: Advance Payment from 2027

Kazakhstan is considering changes to the procedure for paying VAT on goods imported from the member states of the Eurasian Economic Union (EAEU). The draft amendments to the Tax Code provide for certain categories of taxpayers to pay VAT before goods are imported into the Republic of Kazakhstan. The proposed mechanism will be based on the information contained in the accompanying consignment note for goods. If the amendments are adopted, the new procedure is planned to take effect from January 1, 2027. The draft is currently under public discussion until September 25, 2026, meaning that the proposed provisions are not yet final.

 

Current VAT Payment Procedure for Imports from the EAEU

Under the current procedure, VAT on goods imported from EAEU member states is paid after the goods have been imported. The taxpayer submits an application for the import of goods and payment of indirect taxes using Form 328.00. VAT must be paid no later than the 20th day of the month following the tax period in which the imported goods were recognized in the accounting records. Therefore, the current mechanism does not require advance payment of VAT before the goods are actually imported. For companies that regularly import goods from EAEU member states, the existing procedure allows tax liabilities to be determined after the relevant goods have been recognized in the accounting records and the required procedures to be completed within the established timeframe.

 

What Is Proposed to Change from 2027

The draft provides for Article 530 of the Tax Code to be supplemented with a new paragraph 5-1. Under the proposed provision, certain categories of taxpayers will be required to pay VAT on goods imported from the EAEU before the goods are brought into Kazakhstan. The relevant obligation will be determined based on the information contained in the accompanying consignment note for goods. At the same time, the draft does not directly specify the categories of taxpayers to which the new mechanism will apply. The categories of taxpayers and the procedure for advance payment of VAT will be determined by the authorized body. Therefore, at this stage, it cannot be stated that the advance VAT payment procedure will apply to all companies importing goods from EAEU member states. Its application will depend on the subsequent determination of the relevant taxpayer categories and payment procedure.

 

How the VAT Amount Will Be Determined

A separate provision of the draft concerns the determination of the tax base in cases where the value of imported goods stated in the accompanying consignment note is below the established minimum price level. If the value specified in the accompanying consignment note is lower than the minimum price level applied in accordance with Article 518 of the Tax Code, the VAT amount will be determined based on the minimum price level. Therefore, under the proposed mechanism, both the information provided by the taxpayer in the accompanying consignment note and its correlation with the applicable minimum price level will be relevant in cases provided for by law.

 

When the Changes May Take Effect

The proposed provision is planned to take effect from January 1, 2027, together with the main package of amendments to the Tax Code. At present, however, these are still draft legislative amendments. Public discussion of the draft continues until September 25, 2026, so companies importing goods from EAEU member states should take into account the draft status of the initiative and refer to the final wording of the provisions once the review process has been completed.

 

FChain Services for Businesses

Changes to the VAT payment procedure for imports may require businesses to take new tax requirements into account in a timely manner and ensure that import transactions are properly reflected in their accounting records. FChain provides comprehensive accounting and legal support to companies in Kazakhstan.

• Accounting and Tax Services — maintaining a company’s accounting and tax records in accordance with its business transactions and applicable requirements.
• Accounting Recovery — restoring accounting records and documentation and bringing them into proper order.
• Legal Services — professional legal support on matters arising in the course of a company’s business activities.
• Legal Support for Business — comprehensive legal support for ongoing business activities and related legal matters.
• Legal Audit — reviewing a company’s activities and documentation to identify potential legal risks and matters requiring additional attention.

FChain’s comprehensive approach enables companies to combine accounting, tax, and legal support through a single professional team while focusing on the development of their core business.

 

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Prepared by: Anel Kosmaganbetova

Assistant to the Director

FChain Kazakhstan

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