Scope of Activity Covered by the Analysis

1. Development and Operation of Information Systems

1) Name of Corruption Risk
Justification and completeness of requested documents during a tax audit.

Detailed Description of the Process Containing the Corruption Risk
In order to ensure transparency of tax control procedures and minimize corruption risks, it is proposed to enhance the functionality of the information system “Integrated Tax Administration System” (hereinafter – ITAS) in terms of fulfilling requests for document submission.

Currently, the information system provides the function of sending requests for documents to the taxpayer’s personal account.

Recommendations for Risk Mitigation
In this regard, it is proposed to introduce a mandatory feature allowing taxpayers to upload the full set of requested documents directly in response to the request, with automatic recording of the date and time of submission.

2) Name of Corruption Risk
Process of executing notifications related to issued electronic invoices.

Detailed Description of the Process Containing the Corruption Risk
The return of an electronic invoice (hereinafter – e-invoice) involves actions by the supplier to cancel a previously issued invoice or to issue a corrected or additional e-invoice for goods, works, or services. At the same time, in accordance with Article 142 of the Tax Code of the Republic of Kazakhstan, if there is no actual performance of work or provision of services, a notification confirming the absence of turnover must be sent (hereinafter – notification).

If the taxpayer disagrees with the fact of turnover indicated in the notification, they may return such e-invoices with appropriate explanations. However, in practice, returning e-invoices via the “Electronic Invoices Information System” (hereinafter – EIS) is difficult. Specifically, even if the supplier disagrees, the return is not possible without confirmation from the buyer, which prevents the taxpayer from independently fulfilling the notification.

Recommendations for Risk Mitigation
In accordance with Article 142 of the Tax Code of the Republic of Kazakhstan, if the taxpayer disagrees with the turnover, they may return the e-invoices and provide explanations.

In this regard, it is proposed to:

introduce a “by notification” status in the EIS for such returned invoices;
set a one-calendar-day deadline for the buyer to agree or disagree;
or eliminate the requirement for buyer approval altogether, with subsequent review.
2. Legal Acts and Internal Documents Regulating the Activities of State Revenue Authorities

1) Name of Corruption Risk
Confirmation of VAT refunds to suppliers based on information provided by SEZ participants.

Detailed Description of the Process Containing the Corruption Risk
According to paragraph 5 of Article 470 of the Tax Code, the Indirect Tax Administration Department of the State Revenue Department of Astana sends a request to the customs post “SEZ Astana – New City.” The post, in turn, sends a request to Special Economic Zone (SEZ) participants to confirm consumption of goods. Based on responses received, the customs post replies to the tax authority.

This process creates a corruption risk, as customs officers may manipulate VAT refund amounts when providing responses.

Recommendations for Risk Mitigation
Exclude from paragraph 5 of Article 470 of the Tax Code the provision stating: “…information from the customs authority is taken into account…”, as it contributes to corruption risks.

2) Name of Corruption Risk
Risk of improper classification of goods for personal use to apply simplified declaration procedures and reduce customs payments.

Detailed Description of the Process Containing the Corruption Risk
During customs clearance of goods sent to individuals via international postal shipments, there are no clearly defined quantitative limits for certain categories of goods or the number of parcels per period. This creates conditions for subjective decision-making by officials when classifying goods as personal or commercial.

Participants in foreign economic activity (FEA) may split commercial consignments into multiple shipments addressed to individuals to benefit from simplified declaration procedures with lower duties.

The absence of clear criteria enables abuse and potential corruption between FEA participants and customs officials.

Recommendations for Risk Mitigation
Establish quantitative limits for individuals and amend subparagraph 3 of paragraph 4 of Article 339 of the Code “On Customs Regulation in the Republic of Kazakhstan” by setting:

no more than 3 units per product type;
no more than 3 parcels per calendar month.

These measures are necessary to properly distinguish personal use goods and prevent misuse of simplified declaration procedures.

3. Implementation of Control and Audit Functions

1) Name of Corruption Risk
Granting unjustified preference to an audited entity during inspections.

Detailed Description of the Process Containing the Corruption Risk
Interaction with FEA participants during customs inspections is carried out manually on paper and involves direct contact with customs officials.

Recommendations for Risk Mitigation
Create a unified digital ecosystem for remote interaction between customs authorities and FEA participants.

Key System Components:

Personal account (user cabinet) for audited entities to receive documents and submit responses electronically;
Automated notification module with SMS and email integration;
Inspector dashboard for initiating inspections and monitoring deadlines.

Operational Mechanism:

Inspector uploads notification into the system;
System sends instant notifications (push, SMS, email);
Delivery to the personal account is legally equivalent to official service;
The audited entity submits documents electronically using a digital signature.

Expected Benefits:

Reduction in inspection time by 30–50%;
Increased transparency;
Cost savings;
Minimization of corruption risks through full digital traceability.

Required Resources:

Integration with existing customs databases;
Development of web interface and SMS infrastructure.

2) Name of Corruption Risk
Direct contact between the audited entity and officials during customs inspections.

Detailed Description of the Process Containing the Corruption Risk
Interaction between officials and audited entities, including on-site inspections, creates opportunities for corruption.

Recommendations for Risk Mitigation
Introduce mandatory issuance of a “Taxpayer Anti-Corruption Memo,” outlining relevant Criminal Code provisions, as well as the rights and obligations of the audited entity, regulated by an internal order of the authority.

Source : https://www.gov.kz/memleket/entities/kgd-astana/press/news/details/1214668?lang=kk