The query “Internet VAT” may refer to different transactions: payment for Internet access, the purchase of goods from an online store, the acquisition of electronic services, or an order placed with a foreign seller. For an accountant in Kazakhstan, the key factor is not how the order is placed, but the substance of the transaction: who the seller and buyer are, what exactly is being purchased, where the turnover takes place, and which documents confirm the transaction. A specific provision of the Tax Code of the Republic of Kazakhstan may be applied only after such classification. The TC RK defines an online platform as an online store and (or) marketplace for the sale of goods, provision of services, and offers to provide services through public telecommunications networks and the Internet, including the ability to place and pay for an order (Art. 8 of the TC RK). For the sale of goods, the date of turnover is determined with due regard to the terms governing the transfer and delivery of the goods.
What VAT Means for Internet Transactions
The Internet itself is merely a communication or sales channel. Placing an order on a website, corresponding by email, or paying through an application does not in itself determine the tax treatment. Online purchases processed in the same way may produce different accounting outcomes if one involves goods, another involves communications services, and a third involves access to a digital product.
Before recording VAT, the accountant should establish:
- the legal status of the seller and buyer;
- the country of registration of each party;
- the subject matter of the agreement: goods, work, services, a licence, a subscription, or access;
- the place where the goods are actually received or the service is used;
- the availability of an agreement, invoice, acceptance certificate, consignment note, electronic invoice, and payment documents;
- the purpose of the purchase and its connection with the organisation’s activities;
- whether there is a return, discount, subscription cancellation, or price adjustment.
Without this information, it is impossible to determine reliably whether VAT arises, which party must fulfil the relevant obligations, and whether the VAT amount charged may be recognised. The payment description in a bank statement or on a website interface does not replace primary documents.
If the transaction specifically concerns payment for Internet access, the agreement with the operator and the billing documents should be reviewed first. If the query concerns sales by the company’s own online store, the analysis should begin with the terms of sale and the status of the buyers. For foreign services, the nature of the acquired right or service and the applicable rules for the cross-border transaction should be examined separately.
VAT on Online Purchases: Goods and Digital Services
When goods are purchased online, it is important to distinguish placing the order from supplying the goods. The accountant will need information about the seller, the route of the goods, the transfer of title to them, delivery, and the documents accompanying the purchase. If the agreement assigns delivery to the supplier, the date of turnover from the sale of the goods may be the date on which the goods are transferred to a person designated by the supplier who performs the delivery; this rule applies subject to the exceptions provided for by the TC RK. When ordering from a foreign store, documents arising from the movement of the goods across the border should also be reviewed if such movement took place.
A digital purchase requires a different analysis. A subscription, software product, cloud service, advertising account, database access, and consultation by video call may appear as identical bank card payments but have different contractual substance. Not every payment to a foreign platform can automatically be assigned to the same category.
To verify a digital purchase, collect:
- the public offer or individual agreement;
- the invoice and proof of payment;
- a description of the tariff and access period;
- the seller’s details specified in the user account;
- documents confirming acceptance of the deliverable, if required;
- correspondence concerning a refund or price change;
- information on who actually uses the purchase.
Bundled offerings require particular attention. For example, the total price may include access to a service, technical support, data storage, and additional work. The accountant should not independently invent the composition of the service: it must be determined from the agreement and the actual terms.
If an employee made the online purchase using their own card, it should additionally be verified whether they acted in the organisation’s interests, whether the expenses were approved, and whether a complete set of supporting documents was provided. A cash register receipt or bank notification alone is generally insufficient for a substantive classification of the transaction.
What an Accountant Should Check in 2026
It is convenient to begin with a transaction record. Record the parties, subject matter, price, currency, order date, time when access was provided or the goods were transferred, and the list of documents received. Then compare this information with the current version of the Tax Code of the Republic of Kazakhstan applicable specifically to the selected type of transaction.
A practical procedure may be as follows:
- Identify the actual seller. The name of the website, payment intermediary, and recipient of the funds may differ.
- Classify the purchase under the agreement, without relying solely on the bank transaction description.
- Verify the place of turnover under the applicable rules.
- Establish which party must issue the tax and primary documents.
- Verify the grounds for recording the amount in the accounting records and tax returns.
- Reconcile the agreement, invoice, payment, and actual receipt of the goods or services.
- Process a return, order cancellation, or price change separately.
The applicable article is selected according to the type of transaction. The concept of an online platform is established by Article 8 of the TC RK, while the date of turnover from the sale of goods is determined under the rules of Article 460 of the TC RK. In particular, the contractual delivery terms and the actual transfer of the goods to the person performing the delivery are relevant. Services, imports, and transactions with non-residents are classified separately based on the substance of the specific transaction.
An accounting policy should not establish a universal rule such as “all online purchases are taxed in the same way.” For recurring payments, a separate register of subscriptions and foreign services should be created, a person responsible for collecting documents should be appointed, and regular checks should be conducted to determine whether the seller, tariff, or contractual terms have changed.
Frequently Asked Questions
Is every online purchase subject to VAT? — The mere fact that an order was placed online is insufficient to answer this question. The subject matter of the transaction, the parties, the place of turnover, and the applicable provisions must be determined. Online stores and marketplaces fall within the concept of an online platform established by the TC RK (Art. 8 of the TC RK).
Does VAT apply to online purchases from a foreign seller? — This depends on whether goods or services are purchased, as well as on the status of the parties and the circumstances of the transaction. A decision should be made after reviewing the agreement and the rules applicable to the relevant cross-border transaction.
Can VAT be recognised on the basis of a bank statement? — A statement confirms the movement of funds but does not fully disclose the substance of the transaction. The set of primary and tax documents required for the specific transaction must be verified.
How should a subscription to a foreign online service be accounted for? — First, determine the substance of the subscription, the seller, the user, and the access period. Then compare the transaction with the provisions applicable to the relevant type of service.
What should be done if an online store issues a refund? — Proof of the refund should be retained, linked to the original purchase, and reviewed to determine whether the previously recorded transaction must be adjusted under the current rules.
Sources
Regulatory basis: Article 8 of the TC RK — the concept of an online platform; Article 460 of the TC RK — the date of turnover from the sale of goods.