--- title: "VAT on Services in 2026: When It Arises and What an Accountant Should Check" country: KZ lang: en author: Сапа Т.И. (https://buhgpt.kz/authors/sapa-ti) date: 2026-10-13 canonical: https://buhgpt.kz/suraqtar/nds-na-uslugi-v-2026-godu-kogda-voznikaet-i-chto-proverit-en source: BuhGPT --- # VAT on Services in 2026: When It Arises and What an Accountant Should Check > **TL;DR:** When VAT Is Charged on Services VAT on services in Kazakhstan in 2026 cannot be determined solely by the name of the contract or whether the service provider is a VAT payer. The accountant must consistently establish the status of the parties, the substance of the transaction, --- When VAT Is Charged on Services VAT on services in Kazakhstan in 2026 cannot be determined solely by the name of the contract or whether the service provider is a VAT payer. The accountant must consistently establish the status of the parties, the substance of the transaction, the place of supply of the service, and whether an applicable special procedure exists. Transactions with foreign counterparties and electronically supplied services require particularly careful analysis: for tax accounting purposes, the actual terms of the transaction are important, not merely the wording in an invoice or acceptance certificate. The use of the same word “services” in contracts does not mean the same tax outcome. Consulting, software development, access to an online service, dental care, and transaction support have different economic substance. Therefore, before recording VAT, it is necessary to examine the subject matter of the contract, the actions actually performed, the result received by the customer, and the transaction documents. Practical review sequence: - Identify the service provider and the customer. - Establish their tax status and country of registration. - Determine exactly which service was actually provided. - Determine its place of supply under the applicable rules. - Verify the grounds for the selected tax treatment. - Compare the contract, acceptance certificate, invoice, and other supporting documents. If a contract combines several independent services, it is advisable to describe and assess each part of the transaction separately. For example, solution development, provision of access to software, and subsequent technical support may have different subject matters, service periods, and supporting documents. Separating such components in the contract and acceptance certificate enables the accountant to link the price to the obligations actually fulfilled. VAT on Imported Services When purchasing a service from a foreign provider, the mere fact that the supplier is located abroad does not provide a definitive answer regarding VAT. For accounting purposes, it is necessary to determine the actual substance of the service, its place of supply, the status of the parties, and the procedure for fulfilling the tax obligation. The description of the payment in a bank document or the supplier’s foreign address does not replace an analysis of the transaction itself. For electronically supplied services, it is necessary to separately document who the seller is, who receives access, exactly what is provided to the user, the subscription period, and the name in which the billing documents are issued. The terms of the public offer should be compared with the invoice, proof of payment, and account details. Without such comparison, the tax treatment cannot be reasonably determined solely from the name of the online service. Before making such a purchase, the accountant should obtain: - the contract or public offer; - a document describing the purchased service; - the foreign supplier’s invoice; - proof of payment; - information about the seller and its country of registration; - information about the period during which access is provided or work is performed. For electronic services, it is important to distinguish between the transfer of goods, the granting of a right, remote access, and the performance of a custom order. Access to a cloud product, a subscription, online functionality, and custom development may be documented similarly, but for accounting purposes they must be described according to the actual substance of the transaction. The internal transaction file should make it possible to identify the user, the access period, the purpose of the purchase, and the link between the payment and a specific invoice. VAT on IT, Legal, and Accounting Services For IT services, it is first necessary to establish exactly what the customer receives: a developed deliverable, a right of use, remote access, support, data storage, or consulting. The wording “IT services” in an acceptance certificate is insufficient for an unambiguous classification of the transaction. The documents must make it possible to link the payment to a specific result, scope of work, or service period. For legal services, it is useful to document the subject matter of the engagement in detail: preparation of documents, representation, consulting, or comprehensive support. The place where the acceptance certificate is signed or a video call is held does not, in itself, describe the entire transaction. For accounting purposes, the parties to the contract, the substance of the engagement, the result, the performance period, and the acceptance procedure specified in the documents are relevant. The same documentary approach applies to accounting services. It is necessary to establish the scope of operations, the service period, the place of business of the parties, and the service provider’s tax status. If the supplier charges VAT, the customer should compare the contract, the primary document, and the service actually provided before recording the corresponding amount. The contract and primary documents should consistently specify: - the exact name of the service; - the period and scope of performance; - the price and payment procedure; - the parties’ obligations regarding document preparation; - the result of the service or the method of confirming its provision. General wording increases the risk of discrepancies between the contract, acceptance certificate, payment, and actual transaction. If the invoice specifies a subscription, the contract specifies a licence, and the acceptance certificate specifies consulting services, the accountant must align the descriptions in the documents with the actual performance and document the basis for the adopted classification. VAT on Exported Services and Medical Care The provision of a service to a foreign customer cannot be classified for VAT purposes solely by the customer’s country of registration or the payment currency. The accountant must establish the actual subject matter of the transaction and the place of supply of the service, and collect documents confirming the status of the parties, the substance of the obligation, and performance of the contract. Before issuing documents to a foreign client, the following should be checked: - the customer’s details and country of registration; - the subject matter and actual result of the service; - the business activity for which the service is purchased; - the acceptance procedure stipulated by the contract; - the consistency of the invoice, acceptance certificate, payment, and contractual terms. Dental and other medical services should also be described according to their specific type. For accounting purposes, the general description “medical services” or “dentistry” is insufficient: the documents must consistently specify the provider, recipient, substance and period of service provision, price, and basis for settlement. A tax conclusion cannot be transferred from one transaction to another merely because both relate to medical care. If an organisation applies special tax conditions under a previously concluded investment contract or agreement, the type and date of the relevant document must be checked. The terms of investment priority projects and agreements on investment obligations concluded before 1 January 2026 remain in effect within the limits expressly established by the transitional provisions (Article 837 of the Tax Code of the RK). A separate rule is provided for investment agreements concluded before 1 January 2026 (Article 838 of the Tax Code of the RK). What an Accountant Should Do Before Closing the Period For each non-standard service, it is useful to prepare a brief internal opinion stating who provides the service, to whom it is provided, what the result consists of, what period the transaction covers, where the place of supply is determined, and the basis on which the VAT accounting treatment was selected. The contract, acceptance certificate or another performance document, invoice, proof of payment, and counterparty information should be attached to the opinion. Before closing the period, contracts, acceptance certificates, invoices, payments, and accounting entries must be compared. For foreign electronic services, the seller’s details, the account holder, the subscription period, and the purpose of the purchased access must also be checked. Any discrepancies identified must be corrected in the documents whose content does not correspond to the actual transaction. The transitional provisions of the new Tax Code cannot be used as a general basis for determining VAT on ordinary services. For example, Article 833 governs the consideration of applications and claims for a refund of excess VAT submitted before 1 January 2026, rather than the taxation of current supplies of services (Article 833 of the Tax Code of the RK). Article 839 preserves the VAT exemption for imports of raw materials and supplies under certain investment contracts concluded before 1 January 2026; this provision does not apply to imported services (Article 839 of the Tax Code of the RK). Frequently Asked Questions Is VAT charged on all services? — There is no single conclusion applicable to all services. For each transaction, it is necessary to establish the status of the parties, the actual substance, the place of supply, and the basis for the applicable tax treatment. Who fulfils the VAT obligation when electronic services are purchased from a foreign seller? — The answer is determined by the applicable rules, taking into account the place of supply and the status of the seller and buyer. For accounting purposes, the accountant needs documents concerning the seller, buyer, type of service, access period, and payment. Are IT services provided by a foreign supplier subject to VAT? — The general name of the service alone is insufficient to answer this question. It is necessary to determine whether development, access, a right of use, support, data storage, or consulting was purchased and then establish the place of supply of the relevant transaction. Is having a foreign customer sufficient to treat a service as an export? — No. The customer’s country of registration and the foreign currency of payment do not, in themselves, determine the VAT treatment. It is necessary to establish the place of supply and substantiate the substance of the transaction with the contract and primary documents. Does VAT apply to dental services? — The tax treatment is determined for the specific transaction. The documents must specify the type of service provided, the provider, recipient, period, price, and basis for settlement; the word “dentistry” alone is insufficient to draw a conclusion. Sources Tax Code of the Republic of Kazakhstan, Article 833 — transitional procedure for considering applications and claims for a refund of excess VAT. Tax Code of the Republic of Kazakhstan, Article 837 — preservation of the terms of investment priority projects and agreements on investment obligations concluded before 1 January 2026. Tax Code of the Republic of Kazakhstan, Article 838 — preservation of the terms of investment agreements concluded before 1 January 2026. Tax Code of the Republic of Kazakhstan, Article 839 — preservation of the VAT exemption for imports of raw materials and supplies under certain investment contracts concluded before 1 January 2026. --- _BuhGPT — ИИ-помощник для бухгалтеров Казахстана: https://buhgpt.kz_