--- title: "VAT Refund in Kazakhstan in 2026: Conditions and Refund Procedure" country: KZ lang: en author: Сапа Т.И. (https://buhgpt.kz/authors/sapa-ti) date: 2026-10-19 canonical: https://buhgpt.kz/suraqtar/vozmeshchenie-nds-v-kazahstane-v-2026-godu-usloviya-i-por-en source: BuhGPT --- # VAT Refund in Kazakhstan in 2026: Conditions and Refund Procedure > **TL;DR:** In 2026, tax applications and claims for the refund of excess VAT submitted before 1 January 2026 are reviewed in accordance with the procedure and within the time limits stipulated by the Tax Code of the Republic of Kazakhstan dated 25 December 2017 (Art. 833 of the TC RK). T --- In 2026, tax applications and claims for the refund of excess VAT submitted before 1 January 2026 are reviewed in accordance with the procedure and within the time limits stipulated by the Tax Code of the Republic of Kazakhstan dated 25 December 2017 (Art. 833 of the TC RK). This special transitional rule applies to the date on which the application or claim was submitted, so the accountant must first determine exactly when it was filed. What VAT Refundable Means For practical purposes, a distinction should be made between excess VAT, the amount claimed for refund by the taxpayer, and the amount that will be refunded following its review. These figures reflect different stages of VAT processing and therefore cannot automatically be considered equal. The excess may be recorded in tax accounting and in the return, but its existence alone does not confirm that funds will be transferred to a bank account. The amount specified in the refund claim, the results of its review, and the amount actually received are recorded separately. Before recording an expected refund, the accountant should divide the data into three parts: - excess VAT recorded in tax accounting and reporting; - the amount actually claimed for refund by the organisation; - the amount to be recorded following the review of the claim. This separation makes it possible to reconcile the return, the submitted claim, and subsequent decisions, as well as to avoid including the entire excess amount in the payment plan as a guaranteed receipt. A separate breakdown by tax period should be retained for each part. The date of submission of the documents is particularly important in 2026. If a tax application or claim was submitted before 1 January 2026, it continues to be reviewed in accordance with the procedure and time limits of the previous Tax Code, even if the review itself continues after that date (Art. 833 of the TC RK). Procedure for Refunding VAT from the State Budget The process should begin by determining the date on which the claim was submitted. The transitional rule of Article 833 of the TC RK applies to documents submitted before 1 January 2026. Therefore, the procedure and time limits for such claims must be determined by reference to the Tax Code of the Republic of Kazakhstan dated 25 December 2017, which governed this procedure. After determining the applicable procedure, the accountant reconciles the claim amount with the VAT return, tax and accounting registers, electronic invoices and source documents. This reconciliation is necessary so that the organisation can consistently explain how each part of the claimed amount was calculated. The practical procedure is as follows: - Record the date on which the tax application or refund claim was submitted. - Determine the tax periods in which the excess claimed for refund arose. - Reconcile the claim amount with the figures in the return and its appendices. - Compare sales and purchase turnover with the accounting and tax registers. - Verify the documents on the basis of which the relevant VAT amounts were recorded. - Compare the data in the accounting system with electronic invoices and other electronic documents related to the transactions. - Prepare a breakdown of the claimed amount by period, counterparty, and document. - Keep separate records of received notices, requests, submitted responses, and review results. For a claim submitted before 1 January 2026, the review procedure cannot be determined solely by the date of current correspondence with the state revenue authority. The determining date for the transitional rule is the date on which the tax application or claim itself was submitted (Art. 833 of the TC RK). Particular attention should be paid to discrepancies between source documents, electronic invoices, registers, and the return. Errors in dates, amounts, party identifiers, descriptions of goods, work, or services, as well as in the statuses of electronic documents, make it more difficult to substantiate the calculation of the claimed amount. It is advisable to record all stages in an internal checklist: the filing date, reporting period, claimed amount, list of supporting documents, requests received, response dates, and review result. Such records help avoid confusing the amount initially claimed with the amount determined later. How to Prepare VAT for Refund Before submitting the reporting and claim, it is advisable to conduct an internal review of the entire chain by which the amount was calculated. A trial balance alone is insufficient for such reconciliation: the final figure should be broken down to the transactions and documents on the basis of which it was recorded. The accountant should verify: - the availability and accuracy of electronic invoices for the transactions included in the calculation; - the consistency of amounts in electronic invoices, source documents, and the accounting system; - the correctness of the tax period in which each amount was recorded; - the absence of documents that were recorded more than once, withdrawn, cancelled, or replaced; - whether the content of the documents corresponds to the transaction actually recorded; - the correct recording of returns, changes to transaction terms, and corrected documents; - the consistency of counterparties’ and contracts’ details across related documents; - the availability of documents confirming the performance of the relevant transactions; - whether the final breakdown corresponds to the figures in the return and the amount claimed for refund. If the accounting system shows one amount and the electronic invoice information system shows another, the reason for the discrepancy should be determined before the disputed portion is included in the calculation. To do this, the data are compared by document and line item: dates, numbers, amounts, party details, and the status of electronic invoices are checked. Accounting corrections must correspond to the actual circumstances of the transaction and the executed documents. It is useful to prepare a separate register of the claimed amount. It can link each transaction to the contract, source document, electronic invoice, payment document, tax period, and reporting line. The register is also a convenient place to record corrected documents and the reasons for changes to the original data. If the claim has already been submitted, the register should retain the exact version of the calculation that corresponded to the data as at the submission date. Subsequent corrections and explanations should preferably be recorded separately so that the history of changes to the amount remains visible. For applications and claims submitted before 1 January 2026, the control calendar must be prepared taking into account the procedure and time limits of the previous Tax Code, since this is stipulated by the transitional provision (Art. 833 of the TC RK). The dates on which documents were sent and received must be confirmed by the registration or electronic data available to the organisation. VAT Refund under a Bank Guarantee A bank guarantee cannot be regarded as a universal basis for a VAT refund. Article 833 of the TC RK governs only the transitional procedure for reviewing applications and claims submitted before 1 January 2026 and does not establish a separate refund procedure under a bank guarantee. Therefore, the existence of a guarantee does not in itself replace the need to determine the applicable procedure, reconcile the return, and prepare the calculation of the claimed amount. Documents relating to the refund claim and documents relating to the guarantee should be kept separately in the working file so that their purposes are not confused. Before recording the transaction, the accountant must have documents that expressly specify the role of the guarantee, the secured amount, its validity period, and its link to a specific claim. The wording of the bank document must be compared with the organisation’s documents and the information concerning the submitted claim. If the claim was submitted before 1 January 2026, the transitional rule on applying the previous procedure and time limits remains in effect regardless of when in 2026 the organisation executes the related documents (Art. 833 of the TC RK). The key date for applying this provision remains the date on which the application or claim was filed. In the payment plan, the expected amount should be separated from funds already confirmed as received. This makes it possible to account for the continuation of the review, requests for additional explanations, and differences between the claimed and final amounts without prematurely recognising the entire amount as available cash. Frequently Asked Questions What is VAT refundable? — For accounting purposes, this is the amount of excess VAT claimed for refund, which should be distinguished from the total excess, the result of the claim review, and the amount actually transferred. What rule applies in 2026 to previously submitted claims? — Tax applications and claims for the refund of excess VAT submitted before 1 January 2026 are reviewed in accordance with the procedure and within the time limits stipulated by the Tax Code of the Republic of Kazakhstan dated 25 December 2017 (Art. 833 of the TC RK). Can the entire excess VAT be treated as the amount of the forthcoming refund? — These figures should be recorded separately. The working registers must separately show the total excess, the amount claimed, the review result, and the actual receipt. What documents should be prepared for a VAT refund from the state budget? — The document package is compiled taking into account the transactions included in the claimed amount. Tax reporting, electronic invoices, source and payment documents, contracts, accounting registers, and a detailed breakdown of the claim are used for internal reconciliation. What should be done if electronic invoice data do not match the accounting records? — The source of the discrepancy must be identified, the documents compared by line item and details, and then corrections supported by documents must be recorded. The history of changes should be retained together with the original breakdown. Which date is important for applying the transitional procedure? — The date on which the tax application or refund claim was submitted. If the document was submitted before 1 January 2026, the transitional rule of Article 833 of the TC RK applies. Does a bank guarantee guarantee a VAT refund? — The existence of a bank guarantee does not in itself confirm the final refund amount. Article 833 of the TC RK does not establish a special refund mechanism under such a guarantee; it sets out the transitional procedure for applications and claims submitted before 1 January 2026. --- _BuhGPT — ИИ-помощник для бухгалтеров Казахстана: https://buhgpt.kz_