In 2026, when importing, an accountant must determine whether the imported goods constitute taxable imports, and when exporting, confirm the exportation with a contract, declaration, and shipping documents: these rules are established by Art. 451 and 467 of the Tax Code of the RK.
What Is Considered Export and Import for Accounting Purposes
For an accountant, export and import involve more than merely shipping or receiving goods. A transaction simultaneously affects contractual settlements with a non-resident, the movement of goods, source documents, and, where applicable, customs clearance. Therefore, the tax classification of a transaction should be compared with its actual substance and supporting documentation.
For imports, it is first necessary to establish whether the goods fall within the definition of taxable imports. These include goods imported or brought into the territory of EAEU member states that are subject to declaration in accordance with the customs legislation of the EAEU and/or Kazakhstan. Goods exempt from VAT in accordance with Art. 479 of the Tax Code of the RK are excluded (Art. 451 of the Tax Code of the RK).
This provision leads to a practical conclusion: the mere presence of a foreign supplier is insufficient to determine the tax treatment of a particular supply. The accountant must compare information about the goods, the direction of their movement, and customs declaration with the transaction documents. If an exemption applies to the goods, the grounds and supporting documents should be determined under the relevant provision of Art. 479 of the Tax Code of the RK.
When exporting goods, it must be taken into account that removal from the customs territory of the EAEU is recognized as export if carried out in accordance with the customs legislation of the EAEU and/or Kazakhstan. Turnover from the sale of such goods, except for the exclusions stipulated by the Tax Code of the RK, is subject to the zero rate (Art. 467 of the Tax Code of the RK).
To confirm export, Art. 467 of the Tax Code of the RK provides for a set of documents that includes a contract for the supply of exported goods, a copy of the goods declaration bearing the required endorsements, and copies of shipping documents. Special supporting documents are prescribed for certain methods of exportation and types of goods (Art. 467 of the Tax Code of the RK).
Foreign Currency Contract and Repatriation of Funds
When working under a contract with a non-resident, it is important for the accountant to organize settlement controls so that the terms of the contract can be compared with the actual payment, delivery, acceptance of the goods, and refund of any unused advance payment.
The contract should clearly specify delivery and payment deadlines, the currency of the obligation, the acceptance procedure, the terms for refunding the advance payment, and the consequences of partial performance. This information is used when reviewing bank and source documents and makes it possible to determine each party's outstanding obligations.
If the non-resident performs its obligation in stages, the accountant must reconcile each delivery and each payment. The amounts paid, the value of the accepted goods, and the unperformed balance must be linked to the relevant terms of the contract and supplementary agreements.
Any change to the deadline for delivery, payment, or refund of funds should be documented. The new terms must be promptly reflected in the transaction working file so that the contract, bank documents, goods documents, and accounting records contain consistent information.
Before signing the contract, the accountant should check:
- whether deadlines for the non-resident's performance of obligations have been established;
- whether the payment procedure and the terms for refunding the advance payment have been agreed;
- whether the currency of the obligation and the settlement procedure have been specified;
- whether the information about the parties and settlements is consistent in the contract, invoice, and bank documents;
- whether documentary confirmation of delivery, acceptance, and payment is provided for;
- whether a procedure has been established for partial performance or changes to the terms of the transaction.
If the terms of the transaction change, the accountant should compare the supplementary agreement with payments and deliveries previously made. The performed portion of the contract, the outstanding obligation, and the documents forming the basis for changes to the deadlines or settlement amount should be recorded separately.
Permits for Certain Goods
Before the goods are moved, the accountant should obtain information from the responsible departments about their name, characteristics, commodity classification code, and documents accompanying the import or export. This information is also required to properly compare the contract, declaration, and shipping documents.
The tax classification of imports is based on whether the goods are subject to declaration and whether a VAT exemption applies (Art. 451 of the Tax Code of the RK). Therefore, the goods documents must make it possible to identify the supply and match it to the information declared during customs clearance.
Article 479 of the Tax Code of the RK contains a list of cases in which imports are exempt from VAT. In particular, it includes certain types of goods and goods placed under a customs procedure that provides for exemption from taxes. For several grounds, the article expressly requires supporting documents or confirmation from the authorized body (Art. 479 of the Tax Code of the RK).
If goods are imported from the territory of an EAEU member state, the exemption rules prescribed for imports into the EAEU must be considered separately. For example, an exemption is provided for goods imported for warranty servicing under a contract; the supporting documents are the contract, shipping documents, claim, and defect report confirmed by the parties to the contract (Art. 525 of the Tax Code of the RK).
The document review must not be postponed until the shipment date. First, the goods and the conditions of their movement should be identified; then the documentation procedure and list of supporting evidence should be determined; after that, they should be compared with the contract and planned settlements.
What an Accountant Should Check for a Transaction
It is convenient to structure the working review by transaction stage.
Before entering into the contract, the information about the counterparty, the subject matter and settlement terms, the deadlines for the non-resident's performance of obligations, the refund procedure, and the characteristics of the goods must be checked. The wording of the contract must make it possible to link subsequent payments and deliveries to a specific obligation.
Before payment or shipment, it should be ensured that the contractual, bank, and goods documents do not contradict one another. For imports, it is necessary to determine whether the goods are subject to declaration and whether there are grounds for VAT exemption under the Tax Code of the RK (Art. 451 and 479 of the Tax Code of the RK).
For exports, the set of supporting documents must be prepared in advance. As a general rule, it includes a supply contract, a copy of the goods declaration bearing the prescribed endorsements, and copies of shipping documents. When goods are transported through a trunk pipeline system or power transmission lines, a goods transfer and acceptance certificate is used instead of shipping documents (Art. 467 of the Tax Code of the RK).
After the transaction has been completed, the accountant compares the contract with the actual payment, delivery, and acceptance. In the event of partial performance, the amount paid, the value of the goods received or transferred, and the outstanding obligations are reconciled separately. Any discrepancies must be explainable by the terms of the contract and documented amendments thereto.
The transaction accounting file should include the contract and its supplements, payment documents, documents evidencing the transfer and acceptance of goods, declarations, and shipping documents. If a VAT exemption applies, the file should include the documents required under the relevant grounds in Art. 479 or 525 of the Tax Code of the RK.
For an export supply, the set of documents should be reviewed with due regard to the method of exportation. Article 467 of the Tax Code of the RK separately specifies documents for temporary and periodic customs declaration, exportation through pipelines or power transmission lines, and the export of an intellectual property asset (Art. 467 of the Tax Code of the RK).
The final reconciliation must demonstrate the connection between the subject matter of the contract, the goods actually moved, the settlement amount, and the tax grounds. This approach helps promptly identify discrepancies in the name, quantity, and value of the goods, the counterparty's details, and the composition of supporting documents.
Frequently Asked Questions
Do imported goods always constitute taxable imports? — No. Goods exempt from VAT under Art. 479 of the Tax Code of the RK are excluded from taxable imports. The grounds for exemption and the documents required for it are determined for the specific goods and import conditions (Art. 451 and 479 of the Tax Code of the RK).
What rule applies to the export of goods? — The removal of goods from the customs territory of the EAEU is recognized as export if the customs legislation of the EAEU and/or Kazakhstan is complied with. Turnover from the sale of exported goods, except for the prescribed exclusions, is subject to the zero rate (Art. 467 of the Tax Code of the RK).
Which documents confirm export? — As a general rule, these are a contract for the supply of exported goods, a copy of the goods declaration bearing the required endorsements, and copies of shipping documents. The supporting documentation has specific features for certain methods of exportation and types of goods (Art. 467 of the Tax Code of the RK).
What should be monitored when an import is paid for in advance? — The accountant must compare the advance payment made with the actual deliveries, acceptance documents, and refund of the unused amount. In the event of partial performance, the outstanding obligation under the contract is determined separately.
How can a VAT exemption for imports be confirmed? — The specific grounds under Art. 479 of the Tax Code of the RK must be determined, and the documents required for those grounds must be collected. For warranty servicing within the EAEU, the contract, shipping documents, claim, and defect report confirmed by the parties to the contract are used (Art. 525 of the Tax Code of the RK).
When should the goods documents be checked? — Before payment, shipment, and physical movement. The information about the goods in the contract, declaration, shipping documents, and acceptance documents must make it possible to identify the same supply.
Sources
- Article 451 of the Tax Code of the RK. Definition of Taxable Imports
- Article 467 of the Tax Code of the RK. Turnover from the Sale of Goods for Export
- Article 479 of the Tax Code of the RK. Imports Exempt from Value Added Tax
- Article 525 of the Tax Code of the RK. Turnover and Imports Exempt from VAT in the EAEU