Issues reviewed by the Tax Code implementation Project Office

The Project Office reviewed, among others, the following issues:

1. Additional support for businesses when implementing the product labeling system¹

The issue of providing additional support to businesses during the implementation of the product labeling system was considered.

In order to reduce the financial burden on businesses, it was proposed to allow a tax deduction of 150% of the actual costs incurred for purchasing equipment used for applying and reading identification means. The proposal was supported, and the relevant amendments will be included in the Tax Code changes package.

2. Extension of the deadline for issuing ESF for non-residents²

A decision was made to extend the deadline for issuing electronic VAT invoices (“ESF”) for non-residents. The deadline will be extended: ESF for non-residents should be issued no later than the last working day preceding the VAT return filing date.

The State Revenue Committee and the “Atameken” National Chamber of Entrepreneurs are finalizing the wording of the provision.

3. Unified payroll tax payment³

At the 14th meeting of the Project Office, First Vice Minister of National Economy Azamat Amrin presented a simplification proposal – to switch to a unified payment, i.e., one payment order instead of eight. The payment will be processed through second-tier banks and the Ministry of Labor’s information systems, and then automatically distributed between the UAPF, SSIF, MHIF, and SRC. The initiative is proposed to be implemented initially on a pilot basis.

The overall payroll tax burden will not change; the effective burden directly on the employer is not 41%, but 17.5%.

At the 16th meeting, participants discussed preparations for the pilot project on payment unification. A mechanism via the taxpayer’s account is being considered: to calculate all obligatory payments, the employer will only need to indicate the employee’s IIN and salary, after which the system will automatically perform the calculations.

4. Calculation of CIT advance payments due to an additional taxable object in 2025⁴

At the 15th meeting, the procedure for calculating and paying CIT advance payments was discussed in connection with the special taxation regime applicable from 1 January 2025 to 1 January 2026, for certain types of income from money market operations.

Under the previous Tax Code, such income for 2025 was taxed at 10%. The tax base was determined only at the end of the tax period and was non-recurring in nature.

It was proposed to amend the rules for calculating CIT advance payments and tax reporting. The Ministry of Finance supported the proposal and took it into consideration. It is expected that the relevant amendments will be included in the Tax Code changes package.

5. Single VAT rate in the healthcare sector⁵

The possibility of introducing a single VAT rate in the healthcare sector was discussed. Participants agreed on the need for a single VAT rate, although discussions continue regarding its level.

From 1 January 2026, certain medicines are VAT exempted, whereas a reduced 5% VAT rate applies to other medicines, increasing to 10% as of 1 January 2027.

The combination of preferential and exempt regimes creates administrative complexity. Serik Zhumangarin instructed to further assess the potential rate and its impact on the sector and the budget.

6. Timing for recognition of non-resident income from unfulfilled advance payments⁶

The new Tax Code reduces the period for recognizing non-residents’ income from unfulfilled advances from 24 to 12 months. This provision is particularly sensitive for capital-intensive and long-term projects.

It was decided to introduce amendments allowing an extended income recognition period as an exception for investors implementing large investment projects, as well as for airlines acquiring aircraft. The need for such exceptions will be confirmed by a conclusion from the relevant sectoral ministry.