In 2026, the per diem amount should be established in the employer’s internal policy; Articles 317, 461, 463 and 466 of the Tax Code of the Republic of Kazakhstan do not establish either the per diem amount or a tax-exempt limit for per diems. Therefore, these provisions cannot be used to substantiate an exemption of per diems from individual income tax or the procedure for taxing any excess. It is important for the accountant to document the business trip separately, determine the number of payable days and apply the provisions of the internal policy consistently to all business trips.
What per diems are and how they differ from other business travel expenses
When documenting a business trip, expenses are usually divided into several categories:
- per diems — the amount established for each day that the employee is on a business trip;
- travel expenses to and from the business trip destination — accounted for on the basis of tickets and other supporting documents;
- accommodation expenses — supported by hotel documents, a rental agreement, a receipt or another payment document;
- other expenses related to the business assignment, if their reimbursement is provided for by the employer’s internal policy.
Per diems differ from travel and accommodation payments in how they are calculated: they are determined based on the number of business trip days and the payment amount established by the employer. Tickets, hotel bills and similar documents substantiate other types of business travel expenses and may also confirm the actual travel dates. The internal policy should describe the reimbursable expenses separately to avoid combining per diems with payments for accommodation, travel and other costs.
Who is affected and how a business trip is documented
An employer sending an employee on a business trip must document its purpose, destination and duration. The following set of documents is usually used for documentation and calculation:
- Business trip order or directive specifying the employee, destination, business purpose and planned travel dates.
- Internal policy — business travel regulations, a collective agreement or another employer document. It establishes the per diem amounts for trips within Kazakhstan and abroad, the procedure for disbursing funds, the list of reimbursable expenses and the rules for submitting documents.
- Employee’s expense report submitted after returning, together with documents for travel, accommodation and other expenses reimbursable under the internal policy.
- Documents confirming the actual travel dates: tickets, boarding passes, accommodation documents and other documents that allow the actual travel period to be compared with the period specified in the order.
If the actual dates differ from the order, the employer should document the change in duration and recalculate the payment under the rules of the internal policy. The documents must make it possible to establish who was sent on the trip, where, for what purpose and for what period. This links the incurred expenses to the business assignment and enables the accountant to verify the calculation.
Taxation of per diems: individual income tax, social payments and deductions
For tax accounting purposes, the accountant must distinguish between the payment amount established by the employer and the amount that may be accounted for under the special rules of the Tax Code of the Republic of Kazakhstan. These amounts cannot automatically be treated as identical.
Tax limit. Articles 317, 461, 463 and 466 of the Tax Code of the Republic of Kazakhstan contain no provision defining the tax-exempt amount of per diems. Article 317 concerns a subsoil user’s expenses for training Kazakhstani personnel and developing the social sector of the regions, rather than business trips (Article 317 of the Tax Code of the Republic of Kazakhstan). Therefore, it does not provide a basis for deducting per diem expenses.
VAT. Article 461 regulates the determination of the turnover from the sale of goods, work and services, Article 463 regulates the amount of turnover when work or services are purchased from a non-resident, and Article 466 regulates the amount of taxable imports (Articles 461, 463, 466 of the Tax Code of the Republic of Kazakhstan). These provisions do not establish rules for subjecting per diems to individual income tax and social payments.
Consequently, the cited articles cannot be used to claim that the entire payment up to the amount specified in the internal policy is exempt from individual income tax while any excess is taxed as salary. When calculating taxes, the accountant applies only the special provision of the current version of the Tax Code of the Republic of Kazakhstan that directly governs employee income and business travel payments. The amount established by the employer is used to calculate the payment itself, but does not in itself substantiate a tax exemption.
For the same reason, the employer’s expenses cannot be deducted solely by reference to Article 317 of the Tax Code of the Republic of Kazakhstan. To account for an expense, its business purpose, documentary evidence and the applicable deduction provision must be identified. It is advisable to present per diems, travel, accommodation and other reimbursable costs separately in the accounting records.
How to calculate per diems: a practical procedure
The practical calculation procedure for an accountant is as follows:
- Determine the actual travel period using the order and documents confirming the departure and return dates. If the dates changed, document the change before making the final calculation.
- Use the per diem amount from the internal policy effective on the travel dates. Different amounts may be established for trips within Kazakhstan and abroad.
- Check the rules for counting days established by the employer: how departure and return days, days in transit, weekends and public holidays are treated.
- Calculate the payment by multiplying the number of payable days by the established per diem amount. Recalculate it if the duration of the trip changes.
- Separately determine the tax treatment of the payment under the special provisions of the Tax Code of the Republic of Kazakhstan concerning employee income and business travel expenses. Do not use Articles 317, 461, 463 or 466 of the Tax Code of the Republic of Kazakhstan for this purpose, as they regulate other matters.
- Compare the final calculation with the advance paid and determine the additional amount payable or refundable in accordance with the employer’s internal procedure.
For an overseas business trip, the payment currency and the applicable conversion procedure must be documented separately. Paragraph 2 of Article 463 of the Tax Code of the Republic of Kazakhstan provides for the official exchange rate on the date of turnover only when paying in foreign currency for work or services purchased from a non-resident (Article 463 of the Tax Code of the Republic of Kazakhstan). This rule cannot automatically be applied to the conversion of an employee’s per diems. The provision directly applicable to the relevant payment and transaction should be used for the calculation.
Deadlines and common errors
The deadline for submitting the report and documents after returning, the procedure for refunding the unused portion of the advance and reimbursing documented excess expenditure are established in the employer’s internal policy. If the business trip was shorter or longer than planned, the accountant compares the order with the actual dates, documents the basis for changing the duration and recalculates the per diems.
Common errors:
- the internal policy does not specify the per diem amount or describe the procedure for counting business trip days;
- the payment is automatically treated as fully tax-exempt solely because its amount was approved by the employer;
- articles of the Tax Code of the Republic of Kazakhstan that do not regulate business travel payments are cited to substantiate the tax treatment;
- travel days are calculated solely according to the original order even though the documents show different dates;
- per diems are combined with travel, accommodation and other reimbursements, making it impossible to verify the calculation of each component;
- a foreign currency conversion rule relating to another transaction is used for an overseas trip;
- a change in the duration of the business trip is not documented and the payment amount is not recalculated.
Frequently asked questions
Is the employer required to pay per diems? — The internal document must define the amount and procedure for paying per diems if the employer provides for such a payment when sending employees on business trips. Articles 317, 461, 463 and 466 of the Tax Code of the Republic of Kazakhstan do not regulate this issue, so they cannot be cited as the basis for such an obligation.
Can per diems be set above the tax limit? — The payment amount and its tax treatment are determined separately. The employer establishes the amount in an internal policy, while the accountant determines the tax consequences under the special provision of the Tax Code of the Republic of Kazakhstan concerning business travel payments. Exceeding the amount established by the employer and exceeding the tax limit are not the same thing.
Are receipts required for meals and incidental expenses? — Per diems are calculated using the established amount and number of days, while travel, accommodation and other reimbursable expenses are supported by the relevant documents. The list of documents and reporting procedure should be established in the internal policy.
How should weekends during a business trip be treated? — The procedure for counting days must be expressly described in the internal policy and aligned with the documents confirming the actual duration of the trip. If the employee was at the business trip destination on a weekend, that day is included in the calculation in accordance with the procedure established by the employer.
Can the exchange rate under Article 463 of the Tax Code of the Republic of Kazakhstan be applied to overseas per diems? — Paragraph 2 of Article 463 applies to payment for work or services purchased from a non-resident and provides for the conversion of the relevant taxable turnover into tenge at the official exchange rate on the date of turnover (Article 463 of the Tax Code of the Republic of Kazakhstan). It does not establish the date for converting an employee’s per diems.
Where can the tax treatment of per diems for 2026 be checked? — The special provision concerning employee income and business travel payments must be found in the current version of the Tax Code of the Republic of Kazakhstan on the official portal of laws and regulations. Articles 317, 461, 463 and 466 cannot be used to determine the tax-exempt per diem limit.