Counter Tax Audit from 2026 - FCHAIN

Starting January 1, 2026, Kazakhstan will implement the Rules for Appointing Counter Tax Audits, approved by Order No. 548 of the Minister of Finance of the Republic of Kazakhstan dated September 30, 2025.

 What is a Counter Tax Audit?

A counter tax audit is an auxiliary audit conducted on counterparties of a taxpayer (or tax agent) under a comprehensive or thematic tax audit. Its purpose is to obtain additional information about transactions, verify their validity and substance, and clarify issues arising during the main audit.

The period of the counter audit must correspond to the period of the main audit and be conducted within the statute of limitations.

 Steps Before the Audit is Appointed

Before initiating a counter tax audit, the tax authorities must:

1. Identify key suppliers and customers with discrepancies in mutual settlements.
2. Reconcile data to determine the origin of goods, works, and services.
3. Send requests for auxiliary audits concerning counterparties with detected violations.

The deadline for executing such requests is no more than 20 working days.

 When Counter Audits Are Not Conducted

Counter tax audits are not appointed for transactions with:

• electricity, heat, water, gas, and telecom providers;
• taxpayers under tax monitoring;
• inactive entities;
• companies under pre-trial investigation for fictitious invoices;
• organizations whose transactions were invalidated by court decision;
• non-residents who are not VAT payers in Kazakhstan.

Grounds for Conducting a Counter Audit

Tax authorities may initiate a counter audit in cases of:

• unrecorded goods or revenue;
• improperly documented transactions (unclear signatures, missing contracts, etc.);
• impossibility of actual transaction execution (lack of resources, transport, warehouses);
• cash, barter, or non-cash operations not reflected in accounting;
• artificial overstatement of VAT credits;
• transactions with companies whose managers are involved in tax-related criminal cases;
• affiliated transactions aimed at inflating expenses;
• information received from government or law enforcement agencies on tax evasion risks.

Additional Provisions

• If a supplier is unable to fulfill obligations but has issued documents, this must be recorded in the audit request.
• Information on terminated requests must be sent to the initiating authority within 3 working days with supporting documents.

International Requests

For counter audits initiated by foreign tax or law enforcement authorities, a special procedure applies.

Before approving such an audit, authorities must:

1. Confirm the existence of a relevant international treaty;
2. Verify the purpose, grounds, and scope of the request;
3. Ensure compliance with Kazakh legislation, including personal data protection and taxpayer rights.

If deemed valid, Kazakhstan’s competent authorities notify the foreign side of the time, place, and conditions of the audit. All key decisions are made by the requested state. Requests that contradict international agreements are not considered. The execution period for international requests is also limited to 20 working days.

 Conclusion

The introduction of new counter tax audit rules marks a major step in strengthening Kazakhstan’s tax control system. Taxpayers and their partners are encouraged to enhance transaction transparency, ensure proper document management, and regularly reconcile accounts.

FChain KZ is ready to help businesses adapt to these changes. Our experts:

• conduct tax and accounting audits;
• identify and mitigate counterparty-related risks;
• prepare companies for counter and comprehensive tax audits;
• provide guidance on tax compliance and the 2026 Tax Code.

With FChain KZ, your business will stay compliant, prepared, and protected in the face of new tax regulations.

For professional support, please contact us at almaty@f-chain.com or via WhatsApp at +7 771 214 1820.

Prepared by:
Moldir Mukhtar
Business Development Specialist

FChain Kazakhstan
October 6, 2025