Proposed changes
The initiative under discussion provides for the possibility of adjusting an accompanying waybill for goods based on the results of a tax audit. 2027 is stated as the proposed commencement date. Until the relevant amendments are adopted and officially published, neither this date nor the mechanism itself can be considered definitively established.
Upon completion of a tax audit, if violations are identified that result, in particular, in the assessment of taxes and payments to the budget, a reduction in losses, or non-confirmation of amounts claimed for refund, the tax authority issues a notice of the tax audit results. The notice and the tax audit report are registered under the same number (Article 171 of the Tax Code of the Republic of Kazakhstan).
Therefore, in practice, it is important to distinguish between the audit report, the notice of its results, and actions involving the AWG. The current provision governing decisions based on audit results determines the content of and procedure for serving the notice, but does not in itself describe a special procedure for adjusting an AWG. The adjustment conditions and procedure must be established before the new grounds can be applied.
Until the amendments are introduced, the current procedure for preparing and processing AWGs must be followed. The publication or discussion of a draft does not independently provide grounds for amending previously issued electronic documents under a procedure that has not yet entered into force.
Who may be affected by the new procedure
The change will be relevant to organizations and individual entrepreneurs that issue AWGs and, following a tax audit, encounter discrepancies between the waybill data, source documents, and the actual movement of goods. Within a company, the new procedure may affect accounting, warehouse operations, logistics, import and export departments, as well as employees responsible for operating the accounting system.
The type of audit conducted and the content of the documents issued by the tax authority must be taken into account. A comprehensive tax audit covers the fulfillment of tax obligations for all types of taxes and payments to the budget, as well as social obligations; it may include matters covered by thematic audits (Article 155 of the Tax Code of the Republic of Kazakhstan).
If the audit concerns a refund of excess VAT, special rules for thematic tax audits apply. In the cases stipulated by the Tax Code, the tax authority draws up an audit report and an accompanying conclusion; the confirmed excess amount is refunded within the time limits established for the relevant grounds for refund (Article 128 of the Tax Code of the Republic of Kazakhstan). These documents should be distinguished from documents used to record the movement of goods.
An AWG discrepancy may involve several sets of accounting data at once. Therefore, when preparing for a possible adjustment, the waybill should be compared with the source documents, information about the goods, and their actual movement. It should also be determined which related records will need to be brought into line after the new procedure is approved.
What the accounting department and responsible employees should prepare
Until a special procedure is introduced, the company can streamline its internal work involving AWG discrepancies. Such preparation will help reconstruct the circumstances of a transaction and compare them with the tax authority's findings.
- designate employees responsible for issuing, confirming, and correcting AWGs;
- ensure the retention of contracts, waybills, transport, warehouse, and other source documents relating to the movement of goods;
- regularly compare AWG information with source documents and accounting system data;
- record the reasons for identified discrepancies and the actions taken by employees to resolve them;
- retain the audit report, the notice of the audit results, and other documents served by the tax authority;
- separately record discrepancies affecting related documents and inventory balances;
- monitor the date and method of receipt of the notice of the tax audit results.
Monitoring the date on which the notice is received is also important for subsequent procedural actions. When sent through the web portal, the notice is deemed served when it is viewed in the taxpayer's personal account. If it is not viewed within three business days after being sent electronically, the notice is served personally against signature or sent by registered mail with acknowledgment of receipt (Article 171 of the Tax Code of the Republic of Kazakhstan).
If the taxpayer disagrees with the notice of the audit results, the taxpayer may appeal it to the authorized body or a court. Filing a complaint or claim suspends enforcement of the notice in the contested part within the scope and for the period stipulated by the Tax Code (Article 191 of the Tax Code of the Republic of Kazakhstan). Appealing a notice and adjusting an AWG are separate actions, so one should not automatically be substituted for the other.
1C users are advised to keep their configuration up to date and monitor the accuracy of data exchange with the E-invoice Information System. The current release branches are 3.0.74.x for “Accounting for Kazakhstan” and 3.1.37.x for “Payroll and HR Management for Kazakhstan.” The specific new adjustment scenario can be applied after the procedure has been approved and implemented in the information systems.
Time frames and further actions
2027 remains the proposed target date for the change under discussion. The effective date, the range of documents eligible for adjustment, and the conditions for applying the mechanism can be determined from the final text of the adopted act and its commencement provisions.
Responsible employees should monitor:
- the adoption and official publication of the amendments;
- the date on which the new mechanism enters into force;
- the list of audit results that may serve as grounds for adjustment;
- the types of tax authority documents required to make an adjustment;
- the time frames and sequence of the taxpayer's actions;
- changes to the AWG form and the functions of the E-invoice Information System;
- updates to the accounting solutions in use.
Until the special mechanism is approved, AWGs should be issued and corrected in accordance with the current procedure. If an audit has already been completed, the accounting department must first determine the content of the report and notice, the date on which they were served, and whether there are grounds for appeal. The notice must contain information on assessed amounts, reduced losses, amounts claimed for refund that were not confirmed, as well as the time limits and place for filing an appeal (Article 171 of the Tax Code of the Republic of Kazakhstan).
If the notice is appealed, enforcement is suspended only in the contested part: when applying to the authorized body, until a decision on the complaint is issued; when applying to a court, from the date the administrative case is accepted for proceedings until the judicial act enters into legal force (Article 191 of the Tax Code of the Republic of Kazakhstan). These consequences should be taken into account when planning subsequent accounting actions.
Frequently asked questions
Can an AWG already be adjusted solely on the basis of tax audit results? — The mere existence of an audit report or a notice of the audit results does not establish a special procedure for adjusting an AWG. Until the relevant amendments are introduced, the current procedures for issuing and correcting the document apply.
Will the new option definitely become available in 2027? — No, 2027 is stated as the proposed date. The final text of the adopted act, its official publication, and its commencement provisions will have legal effect.
What document does the tax authority issue based on the audit results? — If violations listed in the Tax Code are identified, a notice of the tax audit results is issued. It is registered under the same number as the audit report (Article 171 of the Tax Code of the Republic of Kazakhstan).
Do all old AWGs need to be corrected in advance? — The initiative under discussion does not imply an automatic review of all previously issued documents. Until the new procedure is approved, specific discrepancies must be addressed using the current procedures.
Which documents should be retained after an audit? — The audit report, the notice of its results, proof of service, source documents relating to the transaction, information on the movement of goods, and internal records explaining the identified discrepancy.
What should be done if there is disagreement with the notice? — The notice may be appealed to the authorized body or a court. A complaint or claim suspends its enforcement in the contested part for the period stipulated by the Tax Code (Article 191 of the Tax Code of the Republic of Kazakhstan).
Will a 1C update be required? — Practical implementation will be determined by the final procedure and changes to the E-invoice Information System. Users should install official updates for their configuration and apply the new scenario after its regulatory and technical implementation.
Sources
- Tax Code of the Republic of Kazakhstan 2026, Article 171 “Decision Based on Tax Audit Results.”
- Tax Code of the Republic of Kazakhstan 2026, Article 191 “General Provisions on Appealing a Notice of Tax Audit Results and Actions (Inaction) of Tax Authority Officials.”
- Tax Code of the Republic of Kazakhstan 2026, Article 155 “Comprehensive Tax Audit.”
- Tax Code of the Republic of Kazakhstan 2026, Article 128 “Procedure for Refunding an Excess Tax Amount Based on the Results of a Thematic Tax Audit.”