To apply the exemption, it is not sufficient to comply only with the requirement that employees with disabilities constitute at least 51% of the total staff, and that wage expenses for such employees account for at least 51% of the total payroll fund.

It is also necessary to simultaneously meet two additional conditions:

the number of employees with disabilities must be at least 10 persons;

goods, works, or services must be produced (provided) with their direct participation.

Special attention should be paid to the fact that all the above requirements must be met not only in the reporting quarter but also during the four preceding tax periods. Since the VAT tax period is a calendar quarter, the conditions must be fulfilled throughout each month of the relevant quarters.

If in any of these periods the number of employees with disabilities was less than 10 persons, the right to VAT exemption does not apply.

Source : https://www.gov.kz/memleket/entities/kgd-vko/press/news/details/1250114?lang=ru