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Desk Audit of Imports from EAEU Member States - FCHAIN

Desk Audit of Imports from EAEU Member States

 

The State Revenue Committee of the Republic of Kazakhstan continues to conduct desk audits of businesses engaged in foreign trade activities involving imports from member states of the Eurasian Economic Union (EAEU). One of the most common reasons for issuing notifications to taxpayers is the failure to submit the Application for Import of Goods and Payment of Indirect Taxes (Form 328.00).

Today, many companies actively cooperate with suppliers from Russia, Belarus, Kyrgyzstan, and Armenia. However, when carrying out such transactions, it is important not only to properly prepare shipping and commercial documents but also to fulfill tax obligations in accordance with the legislation of the Republic of Kazakhstan.

 

What is a Desk Audit?

A desk audit is a form of tax administration conducted without a tax inspection and without direct interaction with the taxpayer. Its primary purpose is to identify discrepancies between information available in government information systems and the data reflected in tax reports. During the audit process, the State Revenue Committee uses information from various government databases, including data on cross-border movement of goods, customs records, electronic invoices, and submitted tax returns.

If the analysis reveals that goods were imported from EAEU countries without submitting Form 328.00, the taxpayer receives an official notification.

 

What Should Be Done After Receiving a Notification?

According to the Tax Code of the Republic of Kazakhstan, a notification must be fulfilled within 30 business days from the date it is received. A notification is considered fulfilled if:

  • ~ the taxpayer submits the Application for Import of Goods and Payment of Indirect Taxes (Form 328.00), where required by law;
  • ~ the taxpayer provides a written explanation stating the reasons for not submitting the application.

A desk audit allows businesses to independently correct identified discrepancies without undergoing a tax inspection. Therefore, such notifications should not be ignored.

 

Why Is Timely Submission of Form 328.00 Important?

The application for import of goods and payment of indirect taxes is one of the key documents used in mutual trade within the EAEU. It serves as confirmation of indirect tax payment and forms the basis for tax reporting related to import transactions. Late submission may result in inquiries from tax authorities, requests for additional documents, adjustments to tax liabilities, and other undesirable consequences.

Special attention should be paid by companies that regularly import goods, work with multiple suppliers, or conduct significant volumes of foreign trade operations, as the likelihood of discrepancies increases under such circumstances.

 

How to Reduce Tax Risks?

To minimize tax risks, businesses are advised to:

  • ~ regularly monitor notifications in the taxpayer portal;
  • ~ submit Form 328.00 on time;
  • ~ reconcile accounting and tax records;
  • ~ ensure accurate recording of import transactions;
  • ~ maintain complete supporting documentation for foreign trade activities;
  • ~ conduct periodic internal tax reviews.

A systematic approach to tax compliance helps businesses avoid disputes with regulatory authorities and ensures compliance with legal requirements.

 

Accounting and Tax Services from FChain

FChain provides professional accounting and tax services for small, medium-sized, and large businesses. Our specialists support clients in the following areas:

  1. preparation and submission of tax, statistical, and accounting reports;
  2. comprehensive support of accounting and tax processes from start to finish;
  3. organization and maintenance of accurate accounting and tax records;
  4. consulting on VAT and taxation of import transactions.

If your company imports goods from EAEU member states, FChain experts are ready to provide professional support, help ensure compliance with legal requirements, avoid penalties, and reduce tax risks.

 

Accounting and Tax News – June 2026

Prepared by: Moldir Mukhtar

Business Development Specialist

FChain Kazakhstan

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

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